Adiarc 8202009

U.S.
DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION
ARC Charter
Effective Date:
0812012009
SUBJ: Airworthiness Directive Implementation Aviation Rulemaking Conunit1ee
1. Purpose of this Charter. This charter creates the Aviation Rulemaking Committee (ARC) for
Airworthiness Directive Implementation according to the authority oftbe Administrator afthe Federal
Aviation Administration (FAA) under section I06(pX5) ofTitle 49 of the United States Code (49
U.S.C. I06(pX5)). This charter also outlines the committee's organization, responsibilities, and tasks.
2. Audience. This charter applies to members afthe Airworthiness Directive Implementation ARC,
including members of aviation industry, and employees within the Office of the Associate
Administrator for Aviation Safety: Aircraft Certification Service. Flight Standards Service, and
the Office of Rulemaking. The audience for this charter also includes employees of the Office of
General Counsel and the Office of Aviation Policy and Plans.
3. Where to Find this Charter. You can find this charter on the FAA website at
http://wv.'W.faa.Qovlaboutlconunitteeslrulemakim!l.
4. Background. In early March and April 2008, events of suspected noncompliance to airworthiness
directives (AD) prompted US Secretary ofTransponation, Mary E. Peters, to establish an Independent
Review Tearn (IRT) to craft recommendations to improve the current aviation safety system. "This
leam consisted of five aviation and safety experts. Their task was to evaluate and make
recommendations to improve the FAA's implementation of the aviation safety system and its culture
of safety. The IRT issued their final report on September 2,2008. Their report identified 13
recommendations related to ADs, Voluntary Disclosure Program, Culture ofF AA, Safety
Management Systems, Air Transportation Oversight System, and the role ofFAA Inspectors.
a An AD Compliance Review Team (CRT) was also established to review the events that
caused a major disruption to some airline schedules. The team consisted of eight FAA and indusny
subject matter experts. The team reviewed compliance issues related to AD 2006-15-15 (phase 1) and
the general process for developing ADs (Phase 2). The AD CRT drafted a report to document their
findings and recommendations from their Phase I activity. This report noted areas where system
improvements couJd be made.
b. The AD CRT also drafted a report to document their 12 fmdings and recommendations
from their Phase 2 review, which focused on the process of developing and implementing ADs, and
ensuring compliance. Their findings and recommendations do not fundamentally change the AD
process, but provide suggested enhancements and improvements. The findings and recommendations
focus on the areas of: Service Instructions, Aircraft Evaluation Groups (AEGs), Lead Airline Process
(A TA Specification Ill), AD Process and Implementation, Mandatory Continuing Airworthiness
Infonnation, Alternative Methods of Compliance (AMOCs), Crisis CommurUcation. and Part 39
Regulations.
Initiated By: ANM-IOO
0812012009
c. The pwpose of this ARC is to evaluate and address the recommendations of the AD CRT
and those of the IRT relating to airwonhiness directives. Because the recommendations of the fRT
and the AD CRT address actions to be taken by both the FAA and industry, an ARC is necessary to
ensure that further evaluation and implementation of the recommendations adequately considers the
needs and objectives of all stakeholders. Implementation of recommendations may require some
ruJemaking.
5. Organization and Administration of the Airworthiness Directive Implementation ARC. We

will set up a committee of members of the aviation community, including manufacturers and air
carriers, representing diverse viewpoints. FAA participation and support will come from all affected
lines-of-business. ¥!here necessary, the committee may set up specialized work groups that include
invited subject matter expertS from industry and the FAA..
a The committee sponsor is the Associate Administrator for Aviation Safety, who:
(1) Appoints members or organizations to the committee, at her sole discretion;

(2) Receives all comminee recommendations and reports;
(3) Selects industry and FAA co-chairpersons for the committee; and
(4) PrO\;des administrative support for the committee, through the Aircraft Certification
Service (AJR) and Flight Standards Service (AFS).
b. The co-chailjJOrsons will:
(1) Detennine (with other committee members) when a meeting is required (a quorum is
desirable at committee meetings, but not required);
(2) Arrange notification to all members of the time and place of each meeting;
(3) Draft an agenda for each meeting and conduct the meeting;
(4) Keep meeting minutes; and
(5) Provide status updates to the Associate Administrator for Aviation Safety, at 6 months, 12
months and 18 months from the effective date of this charter.
6. Committee Membership. The conunittee wilI consist of about five to ten members, representing
airplane manufacturers, air carriers. FAA. and other aviation indusoy participants. Membership will
be balanced in vie\ovpoints, interests, and knowledge of the committee's objectives and scope.
Committee membership is limited to promote discussion. Active participation and commitment by
members is essential for achieving the committee's objectives. Attendance is essential for continued
membership on the corrunittee. The committee may invite additional participants as subject matter
experts to support specialized work groups.
7. Public Participation. Persons or organizations outside the committee who want to attend a
meeting must get approvaJ in advance of the meeting from a committee co-chairperson or designated
federa1 representative.
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0812012009
8. Committee Procedures and Tasks.
a The committee advises and provides written recommendations 10 the Associate Administrator
for Aviation Safety (AVS-I).
b. Committee tasks include, but are not limited to, the fOllowing:
(I) Establishing work groups to evaluate and address specific recommendations and assigning
IRT and CRT recommendations to each work group.
(2) Developing a program plan and implementation schedule 10 address the specific
recommendations.
(3) Reviewing, approving, and implementing the program plan.
(4) Monitoring progress and status of work groups and resolving issues ntised by those
groups.
(5) Advocating the program plan and implementation actions/schedule with the respective
stakeholder organizations.
c. The committee may propose additional tasks as necessary to the Associate Administrator for
Aviation Safety for approval.
d. The ARC will submit a fmal report detailing recommendations and implementation actions by
24 months from the effective date of this charter. The Associate Administrator for Aviation Safety
may extend this deadline for up to 6 months if it is in the interest of the FAA to do so.
9. Cost and Compensation. The estimated cost to the Federal Government of the Airworthiness
Directive Implementation ARC is $130,000, annually. All travel costs for government employees will
be the responsibility oftbe government employee's organization. Non-govenunent representatives
serve without government compensation and bear all costs of their corrunittee participation.
10. Availability of Records. Subject to the conditions of the Freedom oflnformation Act, 5 U.S.c.
522, records, reports, agendas, working papers, and other doclUTIents made available to, prepared for,
or prepared by the committee will be available for public inspection and copying at the FAA.
Transport Airplane Directornte, 1601 Lind Avenue SW., Renton, WA 98057-3356. Fees will be
charged for information furnished to the public according to the fee schedule in 49 CFR pan 7.
11. C ommittee Term. This committee becomes an entity on the effective date of this charter. The
comminee will remain in existence for a term of24 months unless its term is ended sooner or
extended by the Administrator.
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0812012009
12. Distribution. This charter is distributed to the Office of the Associate Administrator for Aviation
Safety, the Office of the Chief Counsel. the Office of Aviation Policy and Plans, and the Office of
Rulemaking.
Administrator
4
A IRWORTHINESS D IRECTIVE
I MPLEMENTATION
AVIATION RULEMAKING COMMITTEE
FINAL REPORT
August 2011
Prepared for
Ms. Margaret Gilligan
Associate Administrator
Aviation Safety
Federal Aviation Administration
Washington, DC
AIRWORTHINESS DIRECTIVE IMPLEMENTATION
AVIATION RULEMAKING COMMITTEE
Ali Bahrami Terry McVenes

Manager, Transport Airplane Director of Operational
Directorate Regulatory Affairs
Federal Aviation Administration Boeing Commercial Airplanes
Constance Arnold Robert Bernicchi

Director, Safety and Technical Managing Director — Engineering
Affairs Alaska Airlines
Regional Airline Association
William M. Cavitt Steven W. Douglas

Vice President, Engineering, Acting Manager, Aircraft
Planning, and Quality Assurance Maintenance Division
American Airlines Flight Standards Service
Rolf Greiner John Kotnjek

Regulations Manager, Airworthiness Manager,
Regulations and Policies, Montreal Site
Product Integrity Bombardier Aerospace
Airbus
Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page ii

AIRWORTHINESS DIRECTIVE IMPLEMENTATION
AVIATION RULEMAKING COMMITTEE (CONTINUED)
Sarah MacLeod Antonio Victorazzo

Executive Director, Vice President, Product Integrity
Aeronautical Repair Station Embraer
Association
Joseph W. White
Managing Direc tor, Engineering
and Maintenance
Air Transport Association
Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page iii

Acknowledgment
The AD ARC would like to recognize Mr. James J. Ballough, FAA (retired);
Ms. Carol Giles, FAA (retired), Mr. Dec Lee, formerly of Delta Air Lines; and
Mr. Dave Lotterer, RAA (retired) who contributed to the development of the
AD process changes presented in this report.
TABLE OF CONTENTS
LETTER FROM AD ARC CO-CHAIRS ............................................................................. viii
EXECUTIVE SUMMARY ...................................................................................................... ix

BACKGROUND ............................................................................................................................... ix
AD ARC DELIVERABLES ................................................................................................................ ix
REMAINING ISSUES ......................................................................................................................... x
AD ARC RECOMMENDATION.......................................................................................................... xi
CONCLUSION ................................................................................................................................. xi
AD ARC Implementation Action Deliverables ......................................................................... xi
1.0 INTRODUCTION ............................................................................................................ 1
1.1 BACKGROUND ......................................................................................................................... 1
1.2 AD ARC CHARTER ................................................................................................................. 1
1.3 AD ARC COMPOSITION AND ACTIVITY ..................................................................................... 2
1.3.1 AD ARC Meetings ......................................................................................................... 3
1.3.2 Program Plan and Implementation Schedule ............................................................... 3
1.4 SCOPE OF THIS REPORT ......................................................................................................... 3
2.0 AD PROCESS IMPROVEMENTS—WHAT HAS CHANGED? .......................................... 5
2.1 AD ARC PROCESS ................................................................................................................. 6
2.2 PART 39 ................................................................................................................................. 6
2.2.1 Request for Legal Interpretation ................................................................................... 7
2.2.2 AD ARC Air Carrier and Repair Station Industry Member Concerns With the Part 39
Framework and Processes ................................................................................................. 8
2.3 EFFECTIVE AND EFFICIENT AD PROCESS (NEW) .................................................................... 10
2.3.1 Maintenance in ADs .................................................................................................... 10
2.3.2 Later Approved Parts .................................................................................................. 10
2.3.3 Expected Benefits ....................................................................................................... 11
2.4 FAA GUIDANCE .................................................................................................................... 11
2.4.1 FAA Order 8900.1, Flight Standards Information Management System
(New Chapters) ................................................................................................................ 11
2.4.2 FAA Order 8110.103, Alternative Methods of Compliance (Updated) ....................... 13
2.4.3 FAA Airworthiness Directives Manual, FAA–IR–M–8040.1C (Updated) .................... 14
2.4.4 Other FAA Orders (New and Updated)....................................................................... 16
2.4.5 Compliance Times in ADs (Current/New Policy) ........................................................ 16
2.5 ADVISORY CIRCULARS FOR INDUSTRY .................................................................................... 17
2.5.2 Draft AC 20–xxx, Design Approval Holder Best Practices with Regards to
Airworthiness Directives (New)......................................................................................... 19
2.5.3 AC 120–16E, Air Carrier Maintenance Programs, Change 1 (Revised) .................... 25
2.6 AIR TRANSPORT ASSOCIATION GUIDANCE .............................................................................. 26
2.6.1 ATA Specification 111— Airworthiness Concern Coordination Process
(Improvements) ................................................................................................................ 26
2.6.2 ATA iSpec 2200—Information Standards for Aviation Maintenance (Updated) ......... 28
2.7 OTHER GUIDANCE................................................................................................................. 28
2.7.1 Notice N8100.112, Placing Service Information in the Federal Docket Management
System (New) ................................................................................................................... 28
2.7.2 FAA Policy Memoranda (New) ................................................................................... 29
2.7.3 Air Transportation Oversight System Data Collection Tools (Updated) ..................... 30
2.7.4 FAA Mandatory Continuing Airworthiness Instructions (Revised) .............................. 30
2.7.5 Miscellaneous ............................................................................................................. 30
2.8 TRAINING .............................................................................................................................. 31
Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page v

2.8.1 FAA Training (New and Updated Courses) ................................................................ 31
2.8.2 Industry Training (New) .............................................................................................. 32
2.9 SUMMARY OF PRIMARY GUIDANCE IMPLEMENTING AD PROCESS CHANGES ............................ 34
3.0 FOLLOW-ON ACTIONS ............................................................................................... 35
3.1 ADDITIONAL IMPLEMENTATION ACTIONS ................................................................................. 35
3.1.1 FAA Orders ................................................................................................................. 35
3.1.2 S1000D—International Specification for Technical Publications ................................ 35
3.1.3 Advisory Circulars ....................................................................................................... 35
3.1.4 Maintain Airworthiness — Production versus In-service Aircraft ................................ 36
3.2 COMMUNICATION PLAN ......................................................................................................... 36
3.2.1 Completed/Ongoing Communication Activities .......................................................... 36
3.2.2 Future Communication Activities ................................................................................ 36
3.3 AD ARC RECOMMENDATIONS ............................................................................................... 37
3.3.1 Future FAA/industry Actions ....................................................................................... 37
3.3.2 Metrics ........................................................................................................................ 37
4.0 IMPLEMENTATION ACTION TABLE ........................................................................... 40
5.0 CONCLUSION .............................................................................................................. 69
APPENDIX A—SERVICE INFORMATION WORKING GROUP ......................................... A–1

A1.0 INTRODUCTION ................................................................................................................. A–1
A2.0 ASSIGNED TASKS ............................................................................................................. A–1
A2.1 Corrective Action Decision Guidelines ...................................................................... A–2
A2.2 Critical Task Differentiation ....................................................................................... A–4
A2.3 Detailed Instructions (Clarify Figures) ....................................................................... A–6
A2.4 Expedite Service Information Development .............................................................. A–8
A2.5 Flexibility .................................................................................................................. A–11
A2.6 Lead Airline Process................................................................................................ A–12
A2.7 Maintaining Airworthiness ....................................................................................... A–15
A2.8 Maintain Airworthiness—Production versus In-service Maintenance ..................... A–16
A2.9 Simplified Service Bulletin Format........................................................................... A–18
A2.10 Standard Practices ................................................................................................ A–20
A3.0 CONCLUSION .................................................................................................................. A–24
APPENDIX B—AD DEVELOPMENT WORKING GROUP ................................................. B–1
B1.0 INTRODUCTION ................................................................................................................. B–1
B2.0 ASSIGNED TASKS ............................................................................................................. B–1
B2.1 Earlier Service Bulletin Credit.................................................................................... B–2
B2.2 Efficient and Effective AD Process ............................................................................ B–3
B2.3 Ex Parté Communications ......................................................................................... B–6
B2.4 First Compliance Date ............................................................................................... B–7
B2.5 Harmonization ........................................................................................................... B–8
B2.6 Overlapping ADs ....................................................................................................... B–9
B2.7 Posting Service Information .................................................................................... B–11
B3.0 CONCLUSION .................................................................................................................. B–12
APPENDIX C—AD IMPLEMENTATION WORKING GROUP ........................................... C–1
C1.0 INTRODUCTION ................................................................................................................. C–1
C2.0 ASSIGNED TASKS ............................................................................................................. C–1
C2.1 AD Installation and EWIS Training ............................................................................ C–2
C2.2 Air Carrier AD Compliance Process .......................................................................... C–3
C2.3 All AMOCs Global ..................................................................................................... C–5
Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page vi

C2.4 ASIs and AD Prototyping .......................................................................................... C–8
C2.5 CMO Role in AMOC Process .................................................................................. C–10
C2.6 Communication and 24/7 AMOC Process .............................................................. C–12
C2.7 Maintaining AD Configurations................................................................................ C–14
C2.8 Prototype ADs, Work Done Prior to AD .................................................................. C–17
C3.0 CONCLUSION ................................................................................................................. C–19
APPENDIX D—FAA ORGANIZATION/PROCEDURES WORKING GROUP..................... D–1
D1.0 INTRODUCTION ................................................................................................................. D–1
D2.0 ASSIGNED TASKS ............................................................................................................. D–1
D2.1 AD Compliance Planning .......................................................................................... D–3
D2.2 AEG Roles and Responsibilities ............................................................................... D–5
D2.3 ASI Decisionmaking ................................................................................................ D–10
D2.4 Delegation ............................................................................................................... D–14
D2.5 Part 39 ..................................................................................................................... D–16
D3.0 CONCLUSION ................................................................................................................. D–25
APPENDIX E—AD ARC WORKING GROUP MEMBERS AND AD ARC PROGRAM
SUPPORT STAFF ...................................................................................... E–1
AD DEVELOPMENT WORKING GROUP ......................................................................................... E–1
AD IMPLEMENTATION WORKING GROUP ..................................................................................... E–1
FAA ORGANIZATION/PROCEDURES WORKING GROUP ................................................................ E–2
SERVICE INFORMATION WORKING GROUP .................................................................................. E–2
AD ARC PROGRAM SUPPORT STAFF ......................................................................................... E–3
APPENDIX F—ACRONYMS ............................................................................................. F–1
APPENDIX G—AD ARC CHARTER .............................................................................. G–1
APPENDIX H—PROPOSED FAA LEGAL INTERPRETATION ......................................... H–1
APPENDIX I—LIST OF AD ARC DELIVERABLES ........................................................... I–1
Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page vii

LETTER FROM AD ARC CO-CHAIRS
August 20, 2011
Ms. Margaret Gilligan

Associate Administrator for Aviation Safety
800 Independence Avenue, SW
Washington, DC 20591
Dear Associate Administrator Gilligan,
In 2009, the FAA charged the Aviation Rulemaking Committee for Airworthiness
Directive Implementation (AD ARC) to evaluate and address recommendations related to
Airworthiness Directives (ADs) from the Independent Review Team and AD Compliance
Review Team. The AD ARC completed its work and has prepared this final report. Its
contents include a discussion of implementation proposals developed by the AD ARC
working groups, FAA and industry implementation actions, and recommended
follow-on activities.
The AD ARC implementation actions reflect diligent work by the AD ARC and its
working groups. These actions are the products of careful deliberation by FAA and
industry members, combining their collective experience in the aviation community.
On behalf of the AD ARC, it has been an honor and a pleasure to work on this important
initiative. We are confident the implementation actions will improve FAA and industry
AD development and implementation processes to ensure aviation safety while reducing
the potential for fleet wide AD compliance issues.
Sincerely,
Terry McVenes, Director Ali Bahrami, Manager

Operational Regulatory Affairs Transport Airplane Directorate
The Boeing Company Federal Aviation Administration
AD ARC Co-Chair AD ARC Co-Chair
Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page viii

EXECUTIVE SUMMARY
BACKGROUND
This final report responds to the Federal Aviation Administration (FAA) Administrator’s
charter to evaluate and address the Airworthiness Directives Compliance Review Team
(AD CRT) and Independent Review Team (IRT) recommendations regarding
airworthiness directives (AD) processes1. The FAA Administrator chartered the
Aviation Rulemaking Committee for Airworthiness Directive Implementation (AD ARC)
to conduct this evaluation on August 20, 2009.
AD ARC DELIVERABLES
From December 2009 to August 2011 the FAA, airplane manufacturers, industry
associations, and U.S. air carrier representatives participated in the AD ARC and/or one
of its four working groups. The efforts have resulted in the preparation or publication of
new or revised policy and guidance documents as well as associated training and
familiarization programs for industry and the FAA.
Given the 2-year charter timeframe, the AD ARC worked within the framework of
existing regulations. Of the many AD processes improvements, one of the most
significant focused on ensuring only those actions necessary to address the unsafe
condition are prescribed in ADs. Newly created criteria for identifying within service
bulletins (SB) incorporated by reference in ADs the specific actions required for
compliance (RC) will expand the use of existing maintenance programs in accomplishing
actions that do not directly affect the unsafe condition.
The AD ARC developed new industry guidance to improve AD management processes

and enhance effective AD implementation and compliance, including industry and
FAA coordination. New documents emphasize FAA-internal coordination with
appropriate organizations in reviewing and determining AD compliance. Other new
documents will enhance the processing of alternative method of compliance (AMOC)
applications and awareness of approved AMOCs.
1
Airworthiness Directive 2006–15–15, Process Review Technical Report, A review of the development,
implementation, and compliance determinations associated with AD 2006–15–15, June 3, 2009.
Airworthiness Directives, Process Review Technical Report, A review of Title 14, Code of Federal
Regulations, part 39 airworthiness directives process for commercial airplanes, July 8, 2009.
Report of the Independent Review Team, Managing Risks in Civil Aviation, a Review of the FAA’s
Approach to Safety, September 2008.
Report copies are available at http://www.faa.gov/aircraft/air_cert/continued_operation/ad/ad_arc/
Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page ix

In addition, the AD ARC noted that with appropriate resources and on a limited basis, it is
possible to apply some of the AD process improvements to existing ADs. Improvements
to SBs, such as general notes and RC steps, could be used to support AMOCs to, or
revisions of, existing ADs. In addition, communication and coordination process
improvements between the FAA and industry will facilitate resolution of compliance
concerns for existing and future ADs.
Overall, these improvements will enhance AD process efficiencies and effectiveness by—
 Ensuring more precise AD requirements,
 Reducing the need for and reliance on AMOCs, and
 Reducing risk of service disruptions caused by AD issues.
REMAINING ISSUES
Although the AD ARC evaluated and addressed all of the relevant AD CRT and IRT
recommendations, its improvements should reduce but will not eliminate all of the risk
for large-scale service disruptions. Applying certain AD ARC improvements to existing
ADs that contain overly prescriptive actions may be cost-prohibitive. To a lesser extent,
future ADs can expose the FAA and industry to other risks because both operate under a
regulatory framework requiring strict compliance with manufacturer-developed SB steps
incorporated by reference.
The AD ARC discussed the role an operator’s maintenance program plays after installing
an AD-mandated configuration change on in-service aircraft versus maintenance of the
same configuration installed in production on the same make and model aircraft. The
ARC recognized the role of the operator’s maintenance program differs for the same
make and model aircraft depending on whether the configuration change was
incorporated in production or mandated by an AD. Title 14, Code of Federal Regulations
(14 CFR) part 43 (which establishes general performance standards for maintenance)
provides the operator authority to make determinations of continued airworthiness and
make minor changes to the aircraft configuration. On the other hand, the current
interpretation of 14 CFR part 39 (which establishes the process for issuing ADs to
address unsafe conditions) does not recognize part 43 maintenance for compliance
determinations and does not allow the operator to make those determinations on an
identical aircraft configuration mandated by an AD. The ARC’s process improvements
should reduce, but will not eliminate this dichotomy.
Furthermore, as acknowledged by the AD CRT in its task 1 report, there are significant
differences between part 39 and part 43 issues. The ARC’s process improvements should
reduce, but will not eliminate the negative consequences associated with issues that do
not impact safety.
Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page x

AD ARC RECOMMENDATION
The AD ARC recommends executing a communication plan to ensure its products are
publicized and training is available to all stakeholders. Additionally, the ARC
recommends monitoring the implementation and effectiveness of its products, including
completion of any open issues. It has proposed a set of metrics and a case study, the
analysis of which may identify a need to amend some of the guidance developed by
the ARC.
CONCLUSION
The AD ARC has implemented significant improvements to the processes for
AD development and compliance planning and determinations. The improvements
should facilitate AD compliance and provide a greater level of flexibility to operators
without reducing the high level of safety provided by the current AD system. As the
improvements were made under the prevailing interpretation of part 39, future
evaluations will determine their effectiveness.
The AD process improvements will not completely eliminate the exposure of industry
and FAA to large-scale flight cancellations if operators fail to comply with ADs and
part 39 requirements. Recognition that an operator’s part 43 maintenance program
requires airworthiness may further reduce this vulnerability.
AD ARC Implementation Action Deliverables

The following FAA and industry documents incorporate AD process improvements:
 FAA Order 8900.1, Flight Standards Information Management System:
o Aviation Safety Inspector Decisionmaking, Volume 3, Chapter 60, Section 1
(April 23, 2011);
o Aircraft Evaluation Groups, Volume 8, Chapter 2, Section 2 (June 20, 2011);
o Aircraft Evaluation Group Outreach in the Airworthiness Directives Process,
Volume 8, Chapter 2, Section 9 (June 20, 2011);
o Requesting 24/7 Support for AMOCs , Volume 3, Chapter 59, Section 4
(April 12, 2011);
o Processing Alternative Methods of Compliance Proposals to Airworthiness
Directives, Volume 3, Chapter 59, Section 3 (April 12, 2011);
o Processing an AMOC Proposal, Volume 3, Chapter 59, Section 2
(April 12, 2011);
o Evaluating an Airworthiness Directives Management Process; Volume 3,
Chapter 59, Section 1 (June 1, 2011); and
o Risk Management Process, Volume 10, Chapter 3, Section 1
(January 10, 2011).
Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page xi

 FAA Order 8110.103A, Alternative Methods of Compliance2
(September 28, 2010);
 FAA Order 8110.107, Monitor Safety Analyze Data;
 FAA Order 8110.37E, Designated Engineering Representative (DER) Handbook
(March 30, 2011);
 FAA Order 8100.15A, Organization Designation Authorization Procedures
(June 10, 2011);
 FAA AD Manual, FAA–IR–M–8040.1C (May 17, 2010);
 AC 39–9, Airworthiness Directives Management Process3 (June 1, 2011);
 Draft AC 20–xxx, Design Approval Holder Best Practices with Regards to
Airworthiness Directives4 (June 13, 2011);
 Notice N8100.112, Placing Service Information in the Federal Docket
Management System (September 28, 2010);
 ATA Specification 111, Airworthiness Concern Coordination Process5; and
 ATA iSpec 2200, Information Standards for Aviation Maintenance (May 2011).
2
The FAA also issued FAA Order 8110.103A, CHG 1 on June 30, 2011.
3
The FAA plans to issue a Change Notice to this advisory circular (AC) by the end of August 2011.
4
The FAA plans to issue a final AC by the end of 2011.
5
ATA plans to issue the updated ATA Specification 111 by the end of October 2011.
Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page xii

1.0 INTRODUCTION
1.1 BACKGROUND
Based on widespread flight cancellations in March and April 2008 as the result of
compliance issues found during a Federal Aviation Administration (FAA) oversight audit
of airworthiness directives (AD), Mr. Robert A. Sturgell, FAA Acting Administrator,
formed the AD Compliance Review Team (AD CRT) to review (1) the circumstances
surrounding the flight cancellations and the compliance issues associated with
AD 2006–15–15 on MD–80 series airplane wiring (task 1) and (2) the entire AD process
for commercial airplanes (task 2). Concurrently, Ms. Mary E. Peters, the Secretary of
Transportation tasked an Independent Review Team (IRT) to examine the FAA’s safety
culture and its implementation of safety management. The IRT evaluated the FAA’s
AD process as part of its safety review.
In its final report to the Secretary of Transportation6, the IRT presented

13 recommendations, 2 of which focused on the FAA’s management of ADs. The
AD CRT submitted two reports to the FAA Administrator detailing its two-part review.
The task 1 report7 on AD 2006–15–15 provided 4 recommendations and highlighted
18 areas in the AD process where the FAA and manufacturers should make
improvements. The AD CRT also noted areas that required further study during its task 2
review. The task 2 report8 on the AD process for commercial airplanes provided
12 recommendations and identified over 35 desired improvements. The AD CRT task 2
report also recommended the FAA and/or industry charter a working group or working
groups as appropriate to urgently address the AD CRT task 1 and task 2 reports’
recommendations.
1.2 AD ARC CHARTER

On August 20, 2009, Mr. Randall J. Babbitt, FAA Administrator, chartered the Aviation
Rulemaking Committee for Airworthiness Directive Implementation (AD ARC). As
outlined in the charter, the purpose of the ARC is to evaluate and address the
AD CRT recommendations and those IRT recommendations relating to ADs. The charter
specifies that the evaluation and implementation of the recommendations adequately
consider the needs and objectives of all affected parties and recognizes implementation of
recommendations may require rulemaking. The charter further specifies that ARC
membership be balanced in viewpoints, interests, and knowledge of the committee’s
objectives and scope. In particular, membership, consisting of a
5–10-person panel, should represent airplane manufacturers, air carriers, FAA, and other
affected aviation industry groups.
6
Report of the Independent Review Team, Managing Risks in Civil Aviation, a Review of the FAA’s
Approach to Safety, September 2008. This report is available for viewing/download
7
Airworthiness Directive 2006–15–15, Process Review Technical Report, A review of the development,
implementation, and compliance determinations associated with AD 2006-15-15, June 3, 2009.
8
Airworthiness Directives, Process Review Technical Report, A review of Title 14, Code of Federal
Regulations, part 39 airworthiness directives process for commercial airplanes, July 8, 2009.
Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page 1

The charter tasks the AD ARC to establish work groups to evaluate and address the
AD CRT and IRT recommendations, develop a program plan and implementation
schedule, and monitor the progress and status of working group activities. The charter
also tasks the ARC to advise and provide written recommendations to its sponsor,
Ms. Margaret Gilligan, the Associate Administrator for Aviation Safety. The charter
specifies that the ARC co-chairs provide status updates to Ms. Gilligan at 6-month
intervals from the effective date of the charter. In addition, the ARC must submit a final
report to Ms. Gilligan detailing implementation actions and any recommendations by
August 20, 2011. This final report presents the AD ARC’s implementation and follow-on
actions to include recommendations.
A copy of the charter is contained in appendix G to this report.
1.3 AD ARC COMPOSITION AND ACTIVITY

In accordance with the AD ARC charter, the ARC is comprised of members of the
aviation community from U.S. air carriers, FAA personnel from Flight Standards Service
(AFS) and Aircraft Certification Service (AIR), U.S. and foreign airplane manufacturers,
and aviation industry associations representing air carriers and repair stations. Although
not participating as ARC members, the ARC informed engine manufacturers of the
ARC’s activities through the Aerospace Industries Association thus keeping the ARC
membership to a reasonable number. The 11 ARC members are listed on pages ii and iii
of this report.
To fulfill its tasking, the AD ARC formed working groups to evaluate and address the
AD CRT and IRT recommendations. The ARC grouped similar AD CRT and IRT
recommendations (recognizing there is overlap among the recommendations) and formed
four working groups, each corresponding to a phase in the AD process, to evaluate those
recommendations. The working groups were—
 Service Information,
 AD Development,
 AD Implementation, and
 FAA Organization/Procedures.
The AD ARC defined key objectives for each working group. The details of key
objectives and working group assignments are in appendixes A–D to this report.
The working groups’ membership representation generally parallels that of the AD ARC
with expertise focused on the assigned area. In addition, the ARC invited representatives
of foreign aviation authorities to serve as observers on certain working groups. Once
established, each working group assigned a focal lead to direct and manage the
implementation activities, coordinate activities with other working group leads on areas
that overlap, and provide quarterly status updates to the AD ARC. Appendix E to this
report contains a list of working group members and observers.

1.3.1 AD ARC Meetings
The AD ARC held its initial planning meeting on December 8 and 9, 2009,
at FAA Headquarters in Washington, DC. The ARC subsequently held the
following 2-day meetings:
Date Location
January 20 and 21, 2010 Seattle, WA
March 9 and 10, 2010 Washington, DC
June 3 and 4, 2010 Seattle, WA
September 14 and 15, 2010 Arlington, VA
December 14 and 15, 2010 Seattle, WA
February 15 and 16, 2011 Dallas, TX
April 19 and 20, 2011 Washington, DC
May 17 and 18, 2011 Seattle, WA
June 21 and 22, 2011 Arlington, VA
July 7 and 8, 2011 Washington, DC
In addition, the AD ARC held monthly teleconferences in 2010 through August 2011.
The ARC also held ad hoc teleconferences to discuss and resolve difficult issues.
ARC program support prepared minutes of the ARC meetings and teleconferences and
posted them to the ARC SharePoint site for ARC member review.
1.3.2 Program Plan and Implementation Schedule
The AD ARC established a program plan to document success for addressing each
AD CRT and IRT recommendation and to manage timelines, as well as interdependencies
among and between working group activities. The ARC’s program plan focused on
addressing the recommendations and implementing all actions by June 30, 2011. The
ARC identified any actions that could not be fully implemented by June 30, 2011, or that
require additional work in Chapter 3.0 Follow-on Actions.
AD ARC program support posted the program plan on the ARC SharePoint site. In
addition, ARC program support periodically updated the program plan with information
from the working group leads and presented quarterly progress updates to the
ARC members. The ARC also submitted 6-month status updates to Ms. Gilligan as
specified in the AD ARC charter.
1.4 SCOPE OF THIS REPORT

This report has 5 chapters. Chapter 1.0 presents the background of AD ARC’s tasking,
charter, composition, and meeting activities. Chapter 2.0 discusses AD process
improvements based on the ARC implementation actions and presents a flowchart of the

updated AD process. Chapter 3.0 contains a discussion the AD ARC’s communication
plan that includes planned meetings/seminars for FAA and industry to present AD process
changes to the aviation community and metrics identified as follow-on actions by the
ARC. In addition, this chapter discusses implementation actions not completed by
June 30, 2011, and presents projected completion dates for those actions. Chapter 4.0
contains a table of recommendations from the AD CRT and IRT reports and the
corresponding AD ARC implementation actions. Chapter 5.0 presents the ARC’s
conclusions on implementing changes to the AD process based on the AD CRT and
IRT recommendations.
This report has 9 appendixes. Appendixes A through D present the record of each
working group’s assignments, activities, and proposed implementation actions, which
were approved by the AD ARC. In addition, the outcome for each of the working groups’
proposed implementation actions is confirmed or a description of how the actual
implementation differs from the working groups’ proposal is documented in these
appendixes. The appendixes are organized in chronological order of the working groups’
focus on SB/AD development and oversight processes. Appendixes E and F contain
administrative information, such as the list of working group members and invited
observers, program staff, and a list of acronyms related to this report. Appendix G
contains a copy of the AD ARC charter. Appendix H contains a copy of the proposed
AD legal interpretation and the requests for the FAA legal interpretation regarding
specific aspects of part 39. Appendix I contains a list of primary
AD ARC-related deliverables.

2.0 AD PROCESS IMPROVEMENTS—WHAT HAS CHANGED?
The AD ARC is unique in that the FAA Administrator tasked it to evaluate and implement
changes; most ARCs are chartered only to make recommendations that are addressed later.
The AD ARC’s working groups developed 30 proposals to address the AD CRT and
IRT recommendations that prompted the implementation of the following improvements
to the AD process. These improvements affect manufacturer development of service
instructions; FAA AD development and oversight activities; and AD planning,
accomplishment, and maintenance by operators. Note that because of the participation of
three foreign transport-category airplane manufacturers that are subject to different
national regulatory systems and interact with the FAA based on Bilateral Aviation Safety
Agreements, the ARC acknowledged and addressed international compatibility aspects of
any AD process changes as appropriate.
The AD ARC’s implementation actions use the development of new, completely revised,
or updated FAA and industry guidance and training as primary implementation tools of the
AD process changes. The ARC’s success largely depends on the industry adopting the
best practices outlined in the published Advisory Circulars (AC) and Air Transport
Association of America, Inc. (ATA) specifications. The ARC communication plan, which
includes multiple FAA and industry briefings, will encourage the industry to adopt the
recommended best practices. In addition, the FAA plans to issue a communication to
industry to outline the ARC’s activities, implementation deliverables and advocate that
the industry follow the best practices regarding ADs in recently issued FAA and
industry guidance.
Specifically, the AD ARC actions initiated—

(1) The development of new or revised FAA and industry guidance and training;
(2) The release of FAA policy memoranda on specific AD process issues; and
(3) The issuance of a proposed FAA legal interpretation on part 39.
Chapter 2.0 describes the AD ARC initiated actions. Whether the implementation action
policy or guidance is new or revised is indicated in the section heading as ―New‖,
―Revised‖, or ―Updated‖. In addition, expected benefits of process changes are presented.

2.1 AD ARC PROCESS
In December 2009, the AD ARC began to review and analyze each of the AD CRT
recommendations and the IRT recommendations related to ADs with planned
implementation of those recommendations by June 30, 2011. The compressed timeframe
and effort required to evaluate the 18 complex recommendations presented difficulties for
the ARC and its 4 working groups. Under normal circumstances an issue would be
studied, the solution agreed to by all stakeholders, and then the appropriate material (such
as guidance, training, or a rulemaking document) would be drafted and previewed by the
interested parties and published for comment. For this effort, the FAA and industry
drafted guidance documents and developed training materials as the ARC working groups
analyzed and evaluated issues.
Based on agreed concepts within a working group, the working group developed guidance
language as it documented a proposed implementation plan. The working group then
submitted the guidance language to the FAA or submitted a change request or draft
language to ATA to revise certain industry guidance. The FAA incorporated the guidance
language into the appropriate FAA documents and published the document for public
comments. ATA reviewed the change requests and incorporated the suggested changes in
its industry guidance as appropriate.
Although familiar with the working group’s concepts to revise an AD process issue,
AD ARC members usually did not have an opportunity to review the actual FAA guidance
until the public comment process. Members had agreed to this possibility during the
initial meetings because it was the only way to evaluate and implement the
recommendations by June 30, 2011.
Ultimately, the AD ARC addressed each AD CRT and IRT recommendation and
implemented action on most. In the few cases where an AD ARC member disagreed with
the final implementation plans (either the AD ARC member disagreed with the original
AD CRT or IRT recommendation or with the direction or level of detail taken to
implement an action), the position of the AD ARC member’s organization is presented.
2.2 PART 39
One of the AD ARC’s activities centered on the discussion of whether part 39 needed to be
revised (AD CRT task 2 report, recommendation No. 12). Some ARC members believed
the effect of any AD process changes would be limited by the broad regulatory framework
of part 39 that has permitted increasingly detailed service bulletin (SB) instructions
incorporated by reference in ADs, effectively decreasing the role of part 43 maintenance
programs in compliance. Other ARC members believed that clarification of part 39 was
unnecessary and the AD process changes discussed in detail later in this chapter
collectively provide the flexibility sought by operators.

2.2.1 Request for Legal Interpretation
The FAA Organization/Procedures Working Group (FPWG) analyzed recommendation
No. 12 and as a result AFS–300 requested a formal legal interpretation from the
FAA Assistant Chief Counsel for Regulations (AGC–200) on part 39 to help evaluate and
analyze the AD CRT recommendation for the FAA to—
―Review §§ 39.7 and 39.9, and, if necessary, revise those sections to

clarify that AD compliance is an action required of the operator; it is not
necessarily determined by a strict comparison of the aircraft to
AD-specified configurations.‖9
The primary issues the FPWG discussed are—

(1) The continuing obligation for an operator to maintain an AD-mandated
configuration and
(2) The extent of an aircraft operator’s obligation to accomplish actions referenced in
an SB incorporated by reference in an AD beyond those actions necessary to
address the unsafe condition.
A copy of AFS–300’s request is contained in appendix H to this report. In addition, see

section D2.5 of this report for a detailed discussion of the FPWG’s review of this issue.
In addition to AFS–300’s interpretation request, the Aeronautical Repair Station

Association submitted additional considerations and questions to AGC–200. During its
December 2010 meeting, the AD ARC introduced a number of issues about the language
of part 39 and asked AGC–200 to review the situation where an AD requires an action that
is impossible to accomplish. See appendix H to this report for a copy of these
additional requests.
AGC–200 Response
On April 14, 2011, AGC–200 published a proposed AD legal interpretation in the
Federal Register10 for public comment. See appendix H to this report for a copy of the
proposed AD legal interpretation. The FAA requested that comments on the proposed
interpretation be submitted by May 16, 2011.
Request for Extension of Comment Period

On May 17, 2011, the industry members on the AD ARC requested the FAA extend the
comment period for the proposed AD legal interpretation until June 30, 2011, due to the
ramifications of scope and extent of the proposed interpretation. The extension request
also noted additional time for comment was needed for manufacturers, operators,
maintenance organizations, and individual aircraft owner and operators to finish a review
of the proposed interpretation. The FAA extended the comment period to June 30, 2011.
See appendix H to this report for a copy of the published extension of the comment period.
9
AD CRT task 2 report, recommendation No. 12.
10
72 FR 20898, April 14, 2011.

2.2.2 AD ARC Air Carrier and Repair Station Industry Member Concerns
With the Part 39 Framework and Processes
The AD ARC planned to evaluate the FAA’s final legal interpretation on part 39 and its
implications regarding the AD CRT’s general interpretation and concern that:
―Carried to its extreme, the unique status of AD configuration

requirements means that every element of the configuration requirements
of every AD applicable to an aircraft must be in the mandated
configuration without deviation throughout every flight.11‖
However, AGC–200 did not issue a final interpretation before the publication of this
report. The ARC noted that the AD process improvements and published documents may
need to be reviewed upon issuance of a final legal interpretation on ADs.
The AD ARC worked within the regulatory framework of part 39 realizing that its tasking
could not be delayed pending an amendment to part 39. That framework assumed the
AD CRT’s general interpretation of part 39, which was consistent with the proposed
interpretation. The FPWG, in a majority opinion, found that actions of the ARC could
address the issues underlying recommendation No. 12 without revising part 39. The
minority opinion indicated to some ARC members that significant issues with the
regulatory language in part 39 and the assumed interpretation remained. See section D2.5
of this report for a detailed discussion of part 39 issues reviewed by the FPWG.
Some AD ARC members believe the part 39 language and assumed interpretation are too
restrictive because they treat part 43 maintenance programs as irrelevant to
AD compliance determinations. For example, if after flight, an element of an AD
(for example, a screw) is found out of its mandated configuration, neither inspections
or preventive maintenance performed before flight, nor post-flight corrective actions
or planned maintenance alter the fact that the aircraft was, according to the assumed
interpretation, operated in noncompliance with the AD. Further, some have asserted that
the unsafe condition that necessitated the AD would have been ―reintroduced‖.
As discussed previously, the AD ARC’s improvements to processes underlying the broad

framework of part 39 should assist in providing greater flexibility while ensuring
continued operational safety. These enhancements will reduce the potential for
widespread flight cancellations (as occurred in April 2008) and other compliance-related
issues. More fundamental change to part 39 or its interpretation and FAA supporting
policies and practices may be necessary to further reduce and possibly eliminate this risk.
AD ARC air carrier and repair station industry members presented concepts, as
summarized below, that were discussed and documented, but not fully explored by the
ARC. These ARC members believe the development of these concepts could further
enhance the AD processes and made similar comments to the draft part 39 legal
interpretation:
11
AD CRT Task 2 Report, page 30.

 Part 39 should acknowledge that part 43 maintenance programs are the method by
which air carriers/operators must maintain all aspects of airworthiness, including
the maintenance of type design as changed by ADs. This approach is the way
air carriers have, for years, safely maintained the airworthiness of newly-delivered
aircraft, including AD-equivalent design changes installed in production. The
approach would allow air carriers to make minor repairs and alterations to ADs
(which by definition preclude adverse effects on airworthiness) using the same
procedures currently used under part 43 to make changes to safety and other
features of the type design. Major repairs or alterations would require
FAA-approved data such as an approved AMOC.
 Provide for ―terminating action‖ in AD language that clearly transfers the
maintenance of the type design modification to part 43 after the AD is
accomplished. Special decision criteria could be developed for providing
terminating action to ADs that are workmanship or skill-set intensive.
 Describe AD compliance requirements in terms of the new type design
configuration rather than in terms of accomplishment instruction steps.
SB instructions certainly are vital tools, but do not describe their objective in a way
that can be readily incorporated into practical configuration control or used in
realistic compliance determinations. The AD ARC developed guidance for
designating certain SB steps as required for compliance (RC) to address the latter
of these issues. However, the guidance will require serious evaluation after a
period of implementation. The recommended description would focus
requirements on the exact configuration needed to address the unsafe condition in
a manner similar to design changes installed in production. It would minimize the
impact of ADs as ―stand-alone‖, configuration freezes that allow over prescribed
requirements, providing a narrower objective for configuration control and
compliance determinations and less demand for, and reliance on, AMOCs.
The proposed FAA legal interpretation explains that amendment 39–106

(30 FR 8826; July 14, 1965) authorized the FAA, for the first time, to adopt ADs to correct
―unsafe conditions‖ caused by maintenance.12 The AD ARC air carrier and repair station
members found that this explanation transposes a reasonable concern over maintenance
introducing an unsafe condition into an overstated driver of policies and practices under
part 39—concerns over maintenance ―re-introducing‖ an ―unsafe condition‖ by allowing
any deviation from any element of a mandated configuration. These members believe that
risk management principles do not support the outcome of policies that are driven by
concerns over reintroduction of an unsafe condition. They further believe that either an
enduring new FAA legal interpretation of, or amendment to, part 39 and associated policy
changes are needed to acknowledge and re-establish the role of part 43 maintenance
programs in providing continuous airworthiness including accomplishment of the safety
intent of ADs.
12
Proposed Airworthiness Directive Legal Interpretation; 76 FR 20899, April 14, 2011.

2.3 EFFECTIVE AND EFFICIENT AD PROCESS (NEW)
The AD ARC concluded that all of the improvements to the AD process implemented
through the ARC and its working groups will contribute to addressing the
AD CRT recommendation for a more effective and efficient AD process. The AD process
improvements, in conjunction with the current FAA Quality Management System (QMS)13
and the Transport Airplane Directorate (TAD) internal safety management system
processes will help ensure that the AD process is effective and efficient for large transport
airplanes. A more efficient and effective AD process will result from (1) the AD ARC
implementation of the AD CRT recommendations and (2) continued monitoring and
oversight of the internal measures used to evaluate the effectiveness of the ARC-related
process enhancements.
2.3.1 Maintenance in ADs

During an AD ARC meeting in September 2010, the ARC assigned to the
AD Development Working Group (ADWG) the task of addressing maintenance of
mandatory design changes in ADs. The ADWG noted that addressing maintenance in
future ADs would clarify the maintenance requirements for mandatory design changes and
improve the ability of operators to avoid the unintended alteration of those configurations.
Therefore, in future ADs, for certain AD-mandated design changes, the FAA will clearly
state when normal maintenance methods, techniques, and practices can be used as long as
no element of the AD-mandated configuration is modified.
2.3.2 Later Approved Parts

In discussing ways to make the AD process effective and efficient, the AD ARC assigned
the ADWG with the recommendation to minimize the number of AMOCs for ADs that
require design changes. The ADWG recommended allowing use of ―later approved parts‖
without the need for an AMOC when appropriate. For example, if an AD requires
replacement of a –1 part with a –2 part, and a –3 part is subsequently approved as an
alternative to the –2 part, then the objective is to develop a method that would permit the
operator to use –3 part without obtaining an AMOC. The ADWG proposed that service
information include the following definition of ―later approved parts‖—
Design Approval Holder (DAH) design changes approved after the

original issue or revision [X] of the service bulletin.
DAHs and the FAA will decide whether later approved parts are acceptable without an
AMOC during SB and AD development on a case-by-case basis. If the FAA and DAH
find the installation of later approved parts acceptable, it would be stated in the specific
SB, which will be incorporated by reference in the AD.
13
The Office of Aviation Safety (AVS) is an International Standards Organization (ISO) certified
organization. As outlined in FAA Order 8100.5A, Aircraft Certification Mission, Responsibilities,
Relationships, and Programs, the Aircraft Certification (AIR) service within AVS is responsible for the
determination and issuance of ADs.

The ADWG also considered allowing later approved service information in FAA ADs.
However, because service information incorporated by reference in an FAA AD must be
available at the time the AD is issued, the term ―later-approved service information‖
cannot be used in an FAA AD.
2.3.3 Expected Benefits

 Reduction in number of AMOC requests for later approved parts leads to a
reduced burden in operator’s and DAHs requesting and the FAA processing
AMOC approvals.
 Reduction in the number of SBs revised to provide compliance using later
approved part numbers.
2.4 FAA GUIDANCE

2.4.1 FAA Order 8900.1, Flight Standards Information Management System
(New Chapters)
FAA Order 8900.1, Flight Standards Information Management System14 is an electronic
handbook containing all AFS policy and guidance concerning FAA aviation safety
inspector (ASI) job tasks. The order applies to ASI, managers and supervisors, and other
FAA operational and administrative employees. The aviation industry may consult this
order as a reference only. The FAA revised FAA Order 8900.1 to address
AD management, Aircraft Evaluation Group (AEG) roles and responsibilities, AEG
outreach efforts, ASI decision making for AD compliance determinations, and the risk
management process.
AD Management
The FAA added a new chapter for ASIs to FAA Order 8900.1 covering the
AD Management Process, specifically volume 3, chapter 59, section 1. The chapter
addresses the IRT recommendation for the FAA to provide timely information about new
AD requirements and be responsive to any operator that requests assistance in the form of
progress-towards-compliance audits or reviews, in advance of the AD compliance dates.
The AD management process chapter specifies the following six basic elements that an
air carrier could include to create its own effective AD management program:
 Planning,
 Support,
 Provisioning,
 Implementing,
 Recording, and
 Auditing.
14
The order may be viewed or downloaded from http://fsims.faa.gov.

FAA Order 8900.1 also identifies the ASI’s role in the AD compliance planning process.
The order specifies when the operator brings forth issues, concerns, or clarification
requests during AD planning meetings, the ASI’s involvement ensures that the appropriate
FAA office—AEG and/or aircraft certification office (ACO)—is consulted and their
recommendations and guidance are provided as feedback to the operator.
ASI Decisionmaking
The FAA issued a new chapter 60 in FAA Order 8900.1 containing guidance on
ASI decisionmaking relative to AD compliance, and the ASI’s role in the AMOC process.
The guidance requires ASIs to determine the resources needed to solve difficult and
controversial issues so as to eliminate single-person and subjective determinations. ASIs
are directed to seek guidance and technical assistance from internal FAA resources,
including the certificate-holding district office (CHDO), principal inspector (PI), AEG,
ACO, Regional Office and/or appropriate FAA headquarters-level branch. The order
states ASIs should rely on these resources to gather the appropriate information on which
to determine AD compliance and applicability.
FAA Order 8900.1, ASI decisionmaking also includes conducting a detailed risk
management/safety assessment as part of the process for resolving aircraft and possibly
fleet-wide issues and provides a logic flowchart with systematic procedures that guide
decisionmaking. In addition, the order specifies the Risk Management Process (RMP)
(which provides Certificate Management Teams and Certificate Project Teams with
procedures to manage hazards and associate risks) may be used. The FAA also revised
FAA Order 8900.1, volume 10, chapter 3, section 1, Risk Management Process to include
a reference for assessing suspected AD noncompliance issues.
The AD ARC noted that the RMP is a tool available to ASIs for evaluating a potential
AD noncompliance. The ARC agrees with the IRT recommendation that ASIs should not
need to conduct a risk assessment before taking action on an AD noncompliance.
Aircraft Evaluation Group

The AEG15 provides technical consultation to CHDOs and certificate management offices
(CMO) which involves supporting the CHDO and CMO16 on ADs. ASIs have not
typically used the AEG as a resource for resolving AD compliance issues.
FAA Order 8900.1 now contains an ASI decision tool to emphasize the AEG’s
involvement in compliance determinations. The order also identifies the roles and
responsibilities of the AEG and incorporates AEG outreach to AFS field offices in support
of AD implementation by encouraging communication among the ACO, AEG, and ASIs.
15
The AEG is the AFS organization responsible for determining the operational suitability of newly
certificated and modified aircraft and plays a critical role in pilot qualifications, flight crew training,
minimum equipment lists, acceptance, and approval of ICAs for all aircraft, engine and propeller
certifications, and other continuing airworthiness requirements.
16
For ease of reference CMO is used throughout this report to identify the local FAA office responsible for
an air carrier/operator’s certificate. However, note that some operators work with an international field
office (IFO), CHDO, Flight Standards District Office (FSDO); or certificate management unit (CMU).

In addition, the order contains a new section that relates AMOCs to ADs and specifies
actions that would prompt AEG involvement.
Regarding the AD CRT recommendation for an organizational and procedural change to

ensure FAA field offices have a direct link to the AEG, the FAA determined the current
organizational structure was adequate and deemed an increase in AEG staffing would be
more appropriate. The Director of Flight Standards Service (AFS–1) requested and
received an increase in AEG staffing to support these processes.
AMOC Process
FAA Order 8900.1 provides guidance to ASIs about their role in the AMOC process. The
guidance includes a new section on processing AMOC requests. Specifically, the section
provides guidance on how ASIs should coordinate with the AIR and AEG and how the
letters of approval/denial for AMOC proposals should be processed. In addition, the order
contains a new section on how to process 24/7 AMOC urgent support requests. The order
directs ASIs to reference FAA Order 8110.103 for further guidance on the AD and AMOC
process to include how to contact AIR for support through the AEG.
The order includes guidance on global AMOCs. The order explains that a global AMOC
applies to two or more operators and can be used to obtain an AMOC for multiple serial
numbers or makes and models specified in an AD. The guidance states that an AMOC can
be useful if the responsible office receives or expects to receive multiple requests for the
same AMOC. The order provides various examples of global AMOC proposals.
The order also provides guidance to ASIs on determining that an operator has a defined
policy and procedure to identify and determine if an AMOC is necessary. The FAA is in
the process of updating that guidance to identify how an operator's AMOC policy can
facilitate the development of global AMOCs.
Expected Benefits
ASIs now have clear guidance on decisionmaking which includes the appropriate
coordination within the FAA’s organizations to assist ASIs with compliance
determinations and AMOC requests, if needed, and coordination with the AEG to better
resolve noncompliance issues. The guidance emphasizes there should be no single-person
decisionmaking on controversial issues.
2.4.2 FAA Order 8110.103, Alternative Methods of Compliance (Updated)

On September 27, 2010, the FAA issued FAA Order 8110.103A. The revision addressed
the AD CRT recommendations by—
 Providing AEG coordination criteria for AMOC responses;
 Allowing ACOs to delegate authority to review and approve certain AMOC
proposals to DAH structural designees or type certification organization
designation authorization (ODA) holder’s structural unit members; and
 Providing 24/7 AMOC urgent request support guidance.

On June 30, 2011, the FAA issued Order 8110.103A CHG 1 to—
 Expand delegation authority for certain AMOCs to allow additional structural
delegations, including certain global AMOCs, to DAH designees;
 Share AMOCs with DAHs to allow them to identify if global AMOCs
are appropriate;
 Add guidance when an AMOC is not necessary; and
 Revise the criteria for 24/7 AMOC urgent requests from ―AMOC support is needed
to avoid significant air transportation disruptions (i.e., approximately 10 or more
aircraft)‖ to ―AMOC support is needed to avoid significant air transportation
disruptions or substantial impact to an operator.‖
Expected Benefits
 Expanded structural delegation of AMOCs is an efficient use of resources to
reduce the ACO workload and ensures timely issuance of AMOC approvals.
 Promotes consideration of global AMOCs to reduce the potential for multiple
single-airplane/fleet AMOCs, thereby reducing workload for industry and
the FAA.
 Operators that have AD compliance issues or questions with a few aircraft can now
ask their ASI for an AMOC outside of normal business hours, based on defined
criteria. These operators are no longer restricted by ―10 or more aircraft‖ criteria
needed to use the 24/7 AMOC process. The 24/7 AMOC process should reduce
flight cancellations due to potential noncompliance issues outside of normal
business hours.
 Facilitates the issuance of global AMOCs for typographical and
administrative errors.
2.4.3 FAA Airworthiness Directives Manual, FAA–IR–M–8040.1C (Updated)

The FAA revised the AD Manual17 to—
(1) Clarify acceptance of credit for actions accomplished using an earlier revision of
the service information than identified in the AD action;
(2) Include updated policy on ex parté communication that clarifies the meaning of an
ex parté contact and when it is improper, identifies where to record ex parté
communication, and provides helpful precautions and practices during the
rulemaking process; and
(3) Emphasize the AEG specialist’s early involvement in the
AD development process.
17
Issued May 17, 2010.

Earlier SB Credit (Updated)
Chapter 8 of the AD Manual specifies when it is appropriate to provide credit for actions
accomplished using an earlier revision of the service information than that incorporated by
reference in an AD. For example, actions accomplished before the effective date of an AD
in accordance with the procedures specified in an earlier version of the SB may be
considered acceptable for compliance with the corresponding actions specified in the AD.
The aviation safety engineer (ASE) will identify on the AD worksheet whether credit can
be given for actions accomplished using an earlier revision of the service information.
The AD action will then include a compliance paragraph on credit for actions
accomplished using an earlier revision of the service information.
Ex Parté Communications (Updated)

Ex parté communications occur when all parties affected by a rulemaking are not present
during discussions of an issue directly relevant to the proceeding. The AD CRT found that
the FAA’s ex parté policy may be poorly understood by FAA employees and operators.
Therefore, the FAA revised the AD Manual to provide expanded guidance on the meaning
of a proper and improper ex parté contact during the following stages of the AD
rulemaking process:
(1) Before issuance of a notice;
(2) During the comment period on the notice;
(3) After the comment period closes; and
(4) After a meeting is announced to the general public.
AEG
The FAA also revised the AD Manual to incorporate AEG coordination on the
AD worksheet and during coordination of the AD action. The guidance requires an
AEG specialist’s involvement earlier in the AD development process so the AEG can
better determine when to activate an outreach program to a principal inspector.
Expected Benefits
 Providing credit for earlier SB actions reduces AMOC requests and the
corresponding burden for preparing and processing those requests by the operator,
DAHs, and the FAA.
 Clarifying ex parté contact should facilitate appropriate FAA and
industry communication and information gathering to support the
AD development process and promote the proper use of these communications
during AD rulemaking.
 Clarifying AEG involvement early in the AD development process ensures that the
operational perspective is considered and addressed before AD issuance. This
supports AD implementation by reducing the risk for operational issues to be
discovered after AD issuance and facilitates outreach to FAA principal inspectors
when appropriate.

2.4.4 Other FAA Orders (New and Updated)
FAA Order 8110.107, Monitor Safety Analyze Data (New)
On March 12, 2010, the FAA issued FAA Order 8110.107 that introduced the Monitor
Safety/Analyze Data (MSAD) process. The MSAD process is used to—
 Filter, review, analyze, and identify trends in aviation safety data;
 Help the FAA to identify safety issues in the in-service aircraft fleets; and
 Identify corrective actions to mitigate safety risks across the fleet.
The new order defines a process to ensure early AEG involvement in the continued
operational safety decisionmaking process. When ASEs need information for a risk
analysis from AFS, the ASE must either obtain the information through the responsible
AEG or notify the AEG what information needs to be requested directly from ASIs in
the field.
FAA Order 8100.15A, FAA Organization Designation Authorization

Procedures (Updated)
On June 10, 2011, the FAA issued revised FAA Order 8100.15, chapter 8, section 11 that
expanded the delegation of structural AMOCs and delegation of certain global AMOCs for
type certificate (TC), ODA holders. A TC ODA holder may be authorized to approve an
AMOC for specific ADs with structural aspects (that is, structural ADs or ADs involving
other disciplines in which the structure may be affected by a repair, modification, or
alteration). In rare circumstances, when the ODA holder has documented a pattern of
identical approvals, the ODA holder may be authorized to approve a global AMOC.
Additionally, the ODA holder may be authorized to approve global AMOCs for
administrative (non-technical) corrections to an SB referenced in an AD.
FAA Order 8110.37E, FAA Designated Engineering Representative (DER)

Handbook
On March 30, 2011, the FAA issued FAA Order 8110.37E. Chapter 2,
sections 2–6 a(5) and 2–7 c(6) expand delegation of structural AMOCs and delegation
of certain global AMOCs to DAH structural designees. The effective date for this policy
was May 30, 2011.
Expected Benefits
The FAA updated the orders to expand delegations for approving AMOCs and to include
the corresponding changes to the AD process made in other FAA orders. This provides
consistent and standardized guidance to FAA personnel.
2.4.5 Compliance Times in ADs (Current/New Policy)

The AD CRT recommended that at a minimum, the first compliance deadline should
always be stated in the notice of proposed rulemaking (NPRM) and final rule AD. For
NPRMs/ADs with simple compliance times, TAD identifies the compliance times in the
regulatory text of the NPRM and the final rule AD. For other NPRMs/ADs, especially

those with complex compliance times, the SB identifies the specific compliance times and
this information is incorporated by reference in the AD, which provides limited visibility
to the public unless it has access to the SB. In these cases, TAD provides a range of those
compliance times (including the first and last compliance times) in the NPRM preamble
for transport airplane ADs.
The FAA also issued FAA Notice N8110.112, Placing Service Information into the
Federal Docket Management System (FDMS)18, on September 28, 2010, to require the
FAA to post information incorporated by reference in FAA ADs to the FDMS. Posting
SBs that are incorporated by reference in final rules will allow the public to view the
compliance times in the SB. The notice also allows the FAA to post service information
documents that are proposed in an NPRM for incorporation by reference (IBR) if written
consent from the DAH is provided.
Expected Benefits
Improving awareness of compliance times in NPRMs and ADs will (1) provide better
information to the public so that it can submit timely substantive comments on NPRMs
and (2) assist operators with compliance planning.
2.5 ADVISORY CIRCULARS FOR INDUSTRY

2.5.1 AC 39–9, Airworthiness Directives Management Process (New)
The FAA issued this AC to recommend procedures for operators to develop an
AD Management Process. The AC provides best practices for all aircraft operators
AD compliance planning and includes information on ASI involvement in air carrier
AD management processes and AD prototyping. The AC also provides a means for
operators to assess and respond to unsafe conditions and suggests that when developing an
AD management process, an operator consider its size, capabilities, resources, and
equipment. The AC recommends an operator’s AD management process consist of the
following elements:
 Planning (ensures awareness and assigns responsibility for AD requirements);
 Support (consists of engineering, material, and configuration control);
 Provisioning (ascertaining abilities and time to complete the AD and obtaining
materials and kits from DAHs if available);
 Implementing (accomplishing the AD);
 Recording (documenting the previous elements); and
 Auditing (a process to continually verify and validate AD compliance).
The AC presents operators with industry best practices for implementing ADs including
pre-planning, implementation, and AD verification programs. ASI and CMO participation
is encouraged for AD compliance planning and aircraft prototyping.
18
FAA Notices are temporary directives and the FAA will incorporate the information in Notice N8110.112
into the FAA’s next revision of the AD Manual, FAA–IR–M–8040.1.

For compliance planning, the AC includes specific recommendations whereby the operator
reviews work accomplished before the issuance of an AD to determine the suitability of
the method of compliance and/or the need for an AMOC. The AC also suggests the
operator prototype the work instructions to ensure the instructions are clear, compliant,
and repeatable. Accomplishing a prototype of the AD compliance documentation
allows identification and resolution of issues before implementing the instructions on
multiple aircraft.
AD Sampling Program and Physical Verification

The AC recommends a sampling program as an effective method for monitoring ADs for
continued compliance and for verifying that an unintentional alteration has not occurred.
In addition, for an air carrier, its Continuing Analysis and Surveillance System (CASS),
sampling program would use the air carrier’s existing audit and reliability aspects of its
CASS to verify that ADs are evaluated, accomplished, tracked and that no unintentional
alteration of an AD configuration occurred. The AC provides an AD Compliance Physical
Verification Analysis decision flowchart with instructions to assist operators determining
whether physical verification of AD compliance is necessary. The AC further suggests
that ADs included in a sampling program be assigned an inspection task on a
representative number of aircraft within the operator’s fleet to verify continued
AD compliance.
AMOCs
24/7 AMOC Process
The AC contains the FAA’s policy on processing AMOC requests after business hours to
avoid significant air transportation disruptions or substantial impact to an operator due to a
potential AD noncompliance.
Global AMOCs
The AC recommends operators—
 Request global AMOCs when appropriate.
 Include a statement permitting the FAA to share the subject of an AMOC request
with the DAH for its consideration in obtaining a global AMOC.
 Include language in their AMOC request letters to the DAHs that permits the
DAHs to use air carrier fleet AMOC requests as the basis for requesting a global
AMOC.19
19
This language was inadvertently omitted from AC 39–9 dated June 6, 2011. The FAA plans to include
this information in an upcoming Change Notice to the AC.

Coordination on Controversial AD Compliance Issues
The AC recommends that as part of the operator’s AD management process, the
operators/air carriers develop a process to coordinate AD compliance matters with the
local FAA office. This process may reference a conflict resolution process for
circumstances needing immediate resolution. The AC notes that before agreeing with an
operator’s/air carrier’s process, the FAA local office will ensure that the FAA’s role, as
defined in the process, is consistent with FAA policy.
In addition, the AC suggests air carriers that are members of industry associations consider
using established processes such as ATA Specification 111, Airworthiness Concern
Coordination Process (ACCP) or similar processes developed by other associations, for
significant compliance issues that may be widespread and newsworthy. This could
include coordination with associations, regulatory authorities, and DAHs.
Training
AD Awareness. The AC notes that an operator should develop recurrent AD awareness
training to address the specific policies and procedures regarding AD compliance. This
training should include the awareness of strict compliance with written instructions and
the option to propose an AMOC when a deviation from the AD is necessary or desired.
The AC recommends when an operator determines that an AD’s complexity may affect its
implementation, the operator should have a program to determine whether maintenance
training is needed using a risk analysis-based assessment.
Skill-Specific Training. The AC recognizes training may also include skill-specific

training for particular ADs such as the use of a new nondestructive testing (NDT)
technique. The AC also recommends DAHs and operators have an electrical wiring
interconnection system (EWIS) training in place that is consistent with the 2007 Enhanced
Airworthiness Program for Airplane Systems (EAPAS) rule and with the current version
of AC 120–94, Aircraft Electrical Wiring Interconnection Systems Training Program.
Expected Benefits
Although many large operators may have sophisticated AD management processes in
place, the AC provides basic guidelines for all operators to follow when implementing and
maintaining ADs. The guidance on prototyping, AD sampling, and physical verification
are industry best practices that will assist operators in reducing AD noncompliance issues.
In addition, the ASI role as an observer and a coordinator between the operator and the
AEG and ACO during AD compliance planning provides a feedback mechanism on
AD implementation issues and should help reduce future AD noncompliance.
2.5.2 Draft AC 20–xxx, Design Approval Holder Best Practices with Regards
to Airworthiness Directives (New)
The FAA issued draft AC 20–xxx on June 13, 2011, which presents the best practices for
DAHs of aircraft, aircraft engines, propellers, and articles when drafting SBs that are the
subject of an AD. The draft AC addresses a broad range of subjects for DAHs such as
guidance on drafting SBs that will be incorporated by reference in a future AD; a new

process for DAHs to check for overlapping/conflicting ADs; maintaining airworthiness;
ex parté communications; and global AMOCs as discussed below. After incorporating
public comments, the FAA plans to post another draft for comment and issue a final AC by
the end of 2011.
Drafting SBs for ADs

Critical Task Differentiation
Guidance on identifying RC items in SBs (that will be incorporated by reference in an
AD) is included in the second draft AC 20–xxx. Currently, SBs incorporated by reference
in an AD often contain detailed instructions necessary to comprise a complete work
package. The SBs may include procedures such as use of a specific part number or
material that may not be directly related to correcting the unsafe condition in the AD. The
increasing detail in instructions developed over a long period to give operators sufficient
information DAHs consider necessary to ensure that, after SB accomplishments, the
affected airplane represents the respective DAH’s state-of-the-art level of safety and
design quality.
A recent approach to coordinate with the FAA SB content, structure, and level of details
was the ―AD-friendly-SB‖20 initiative involving U.S. and non-U.S. DAHs. The
AD-friendly initiative is designed to identify and implement improvements to format and
usability of SBs for nontechnical issues. A key purpose of the initiative was to avoid
repetition of SB service instructions in ADs, thereby avoiding differences, errors, and
duplication of FAA and operator efforts. However, the initiative also is the latest
evolutionary step toward making modification SBs detailed, ―how to‖ installation
instructions and away from the objective-oriented instructions specified in historical ADs.
The AD ARC noted that the failure to differentiate non-critical tasks21 from critical
tasks results in all steps incorporated by reference in an SB to be accomplished exactly as
written. This can cause over prescription of the AD requirements and requires an AMOC
for any deviation to those steps, even obvious typographical errors. Failure to obtain
an AMOC for any step results in a noncompliance with the AD. The new
AD ARC-developed guidance states only those steps in an SB (incorporated by reference
in an AD) that have a direct effect on addressing an unsafe condition will be identified
as RC.
The AC provides information to help authors and users of the service information
understand the safety intent of the design change, the configuration that corrects the
unsafe condition, and which tasks are necessary to comply with the applicable AD. This
approach separates non-critical tasks such as access to an area in the SB incorporated by
reference in an AD from those required to correct the unsafe condition.
20
See ―Agreed Principles and Practices on AD Friendly Service Bulletins Between the Seattle Aircraft
Certification Office (SACO), Los Angeles Aircraft Certification Office (LAACO) and Boeing Commercial
Airplanes,‖ dated March 31, 2006.
21
Non-critical tasks are tasks specified in service information from which an operator may deviate and not
affect the correction of the unsafe condition.

The AD ARC expects each DAH and regulatory authority will create internal guidance
based on the information in draft AC 20–xxx and parallel information in other industry
documents such as ATA iSpec 220022 and S1000D23 to ensure the standards for identifying
the safety intent, describing the configuration that corrects the unsafe condition, and
identifying the applicable RC tasks during the drafting, review, and approval of SBs.
The AD ARC notes that implementation of the RC concept will differ among the various
DAHs. AD ARC members from Airbus and Bombardier, for example, stated their
companies do not concur with the level of detail contained in the AC to identify RC tasks.
Airbus plans to identify the procedure and test paragraphs of its SBs as RC to remove the
unsafe condition from the aircraft and not identify specific steps. Among other issues,
Airbus cited costs associated with revising its SB authoring system and the lack of a stated
need to separate critical tasks from flexible tasks for its non-U.S. customers.
Bombardier holds a similar position in that it has agreed to identify certain paragraphs of
its SBs as RC, but it will not identify specific steps. Like Airbus, Bombardier will
consider procedure and test paragraphs as critical to ensure removal of the unsafe
condition of the airplane. Bombardier stated operators may deviate from job set-up and
job closeout instructions without interfering with the safety intent of the AD. Bombardier
mentioned similar reasons as Airbus for not adopting the detailed RC approach, one of
which is that there is no regulatory requirement to identify steps within an SB as critical to
correct the unsafe condition. Both DAHs consider their approach to be an equivalent
means to comply with the intent of the recommendation.
The AD ARC further notes that its operator and association members accepted the
approach to identify certain actions as RC but preferred an even more detailed application
of the RC concept. The industry members of the ARC expect that the FAA will further
refine the process for identifying critical tasks as it issues future ADs.
Standard Practices
The AC provides guidance on when not to include procedures in an SB because the
procedures are already published in other DAH documents. In addition, the guidance
suggests standard practices manuals be referenced in the SB. The AC states the phrase ―in
accordance with‖ should be used to identify maintenance procedures that must be
followed. The phrase ―refer to…as an accepted procedure‖ should be used to identify
maintenance procedures that can be used, but for which an operator may use its own
accepted equivalent procedure. A general note describing use of ―in accordance with‖ and
―refer to‖ should be included at the beginning of the SB accomplishment instructions.
22
Information Standards for Aviation Maintenance, Revision 2011.1; May 2011.
23
International specification for technical publications, Issue 4.0, 2008–08–01.

Flexibility/General Notes
The AC includes guidance on the use of general notes in SBs. Some DAHs use general
notes in SBs to provide operators flexibility to use alternate parts, materials, tools, and
processes while still meeting design requirements. Without general notes, detailed
instructions in SBs often lead to an operator not being allowed to use accepted or
approved alternate parts, materials, or processes requiring the operator to submit a request
for an AMOC.
The AC explains that general notes are used to provide information related to the
SB accomplishment instruction steps. Unless specified otherwise, general notes should
also apply to figures, illustrations, and drawings included in the SB. Examples of general
notes include referencing alternative parts, material, and processes; describing tolerances
and dimensions; warnings or cautions; fastener substitutions; a standard practice; and
referring to instances when the specified DAH maintenance documentation must be used.
Streamline Development
The AC suggests each DAH have systems in place to continuously review and implement
process improvements in the development and revision of SBs. The AC provides a list of
possible tools to implement for continuous process improvements. The tools listed
include use of checklists, tip sheets, and boilerplate text; and documented standards
and guidance.
Detailed Instructions
The AC notes an SB must be clear on whether a figure, illustration, or drawing is the
authoritative instruction or only an installation aid. The AC provides guidance and
establishes a standard for illustrations to ensure clarity by employing the
following methods:
 Shade/cross hatch important areas;
 Use of phantom lines for items in illustrations that are for reference only; or
 Use of enlarged views in illustrations (currently a DAH standard practice).
The guidance also specifies that the text in the accomplishment instructions should be the
authoritative information and that figures, illustrations, and drawings should be used to
supplement the accomplishment instructions.
Corrective Action Decision Guidelines

The AD ARC noted an SB specifying numerous compliance times, configurations,
conditions, and alternative corrective actions can be difficult to follow. The AC specifies
that for such cases, a logic-based diagram could serve as a useful tool to assist
owners/operators in choosing the best corrective action path, such as repetitive inspections
or terminating repair, based upon the discovered condition and compliance time. The AC
contains standards for logic-based diagram format, content, and location noting that the
use of such a diagram is only as a supplement to the accomplishment tasks and
compliance times text. ATA added parallel specifications to ATA iSpec 2200. See

section 2.6.2. In addition, the Service Information Working Group (SIWG) is
communicating with the Civil Aviation Working Group responsible for updating S1000D
and will submit a change request in September 2011 to update S1000D to include
guidance on inclusion of logic based diagrams in an upcoming revision to S1000D. See
section 3.1.2.
The AD ARC noted that DAHs developed different ways to introduce logic diagrams
(flowcharts) in SBs. Although all DAHs involved in the AD ARC’s activities follow the
information included in the current ATA iSpec 2200, the status and the location of a logic
diagram within their SBs may differ.
Overlapping/Conflicting ADs
The AC suggests a DAH conduct a review of previously issued ADs and their associated
SBs to identify those that may conflict and/or overlap with the pending or new AD. The
AC encourages DAHs to develop an SB/AD tracking and management system to identify
and address overlaps and conflicts between SB actions. The DAH should search for
potential overlapping and/or conflicting AD requirements and determine whether there are
any existing/planned ADs in or affecting the area of the pending or new AD. The AC
recommends the DAH enable search capability by make/model or part number of affected
product(s); major aircraft structural elements such as engine, strut, wing; ATA code;
maintenance zones; service information (such as by SB number); and previously issued
ADs. The DAH should notify the FAA of the results of its review and resolution of any
conflicting issues when submitting the SB for approval.
The FAA will record on the AD worksheet the list of existing ADs affecting/overlapping
the newly proposed AD actions that could lead to a noncompliance, confirm that no
conflicts exist, and identify whether the DAH confirmed this information.
Maintaining Airworthiness
The AC notes that once a type design is changed by an AD, maintenance can be performed
using a combination of the methods, techniques, and practices prescribed in the DAH
instructions for continued airworthiness (ICA), and an operator’s own maintenance
practices developed under § 43.13(c). If these procedures fail to take AD-mandated
requirements into consideration, including detailed configuration requirements, the
product could become noncompliant with an AD. The AC suggests DAHs perform the
following actions:
 During the design change and SB development stages, evaluate the need for
changes to ICA to eliminate the potential for undoing a mandated condition or
configuration.
 Provide awareness to owners/operators regarding availability of updated
ICA documents.
 When drafting SBs, use general notes for flexibility and refer to standard practices
as much as possible.

 In an SB, do not duplicate procedures that reside in approved or non-approved
(that is, accepted) manuals or other ICA procedures. Place internal flags (only
viewable by the service instruction author) in the procedures in non-approved
manuals and in approved manuals for the purpose of alerting the service
instruction author that the identified data is directly related to an AD.
 Create an SB-to-AD cross reference listing upon release of the AD.
Ex Parté Communications
The AC provides a reference to the FAA AD Manual as well as 14 CFR part 11 for
information on ex parté contacts. See discussion of Ex Parté Communications in
section 2.4.3 on the AD Manual.
Global AMOCs
Global AMOCs24 apply to two or more operators and can be used to obtain an AMOC for
multiple serial numbers or makes and models specified in an AD. The FAA can issue a
global AMOC if the responsible office receives or expects to receive multiple requests for
the same AMOC.
To expand the use of global AMOCs, the AC provides guidance for DAHs to consider
posting global AMOCs on a Web site accessible by operators as well as reviewing
delegated and FAA-approved AMOCs to determine if they are candidates for a global
AMOC. The AC states the DAH’s Web site should have the functionality to search data
on the following fields:
 AD Number,
 Model Effectivity, and
 AMOC approval response or subject of AMOC, as appropriate.
The guidance also specifies that when requesting an AMOC, owners/operators should
consider whether to request the AMOC as global or provide permission to share the
AMOC approval response with the product DAH for its consideration in requesting a
global AMOC. In addition, a permission statement is required for a DAH to consider
whether another AMOC requestor’s proposal should be a global AMOC. The operator’s
written consent must be included in the AMOC request submitted to the FAA.
Expected Benefits
The issuance of the final version of draft AC 20–xxx expects to yield benefits in the
following areas:
 Critical task differentiation using the RC concept will narrow the scope of the
AD requirement thereby reducing the over prescriptiveness of certain new ADs
and reducing the need for AMOCs. The reduction in required steps for an AD will
24
A global AMOC is also known as an AMOC of general applicability.

likely reduce the number of AD compliance questions. Industry may also decide
to apply the RC concept to existing ADs using the AMOC process.
 The incorporation of process improvements such as general notes, clarifying the
use of figures, and adding flexibility for operators and maintenance providers in
the use of standard practices will likely reduce the number AD compliance
questions.
 A reduction in AMOC requests because operators, DAHs, and regulatory
authorities have clear guidance on when an alternate process or procedure can be
used to accomplish certain SB actions.
 Improved processes involving the quality of SBs as well as a reduction in time to
develop and revise SBs. The use of general notes allows operators the option to
use their engineering authority and reduces the burden on the operator and FAA for
processing AMOC requests for steps where operators can use acceptable
alternative materials and approved internal procedures without requesting
an AMOC.
 The standardized format, content, and location of logic-based diagrams will assist
operators with implementing service information accurately and efficiently through
repeated use and increased familiarity and reduce potential for AD noncompliance.
 An operator’s engineering and administrative resource expenditures should be
reduced as more global AMOCs are approved and made widely available
to operators.
 The FAA’s and DAHs’ resource expenditures should be reduced because approving
global AMOCs will reduce the number of times the FAA and/or DAH must review
and approve AMOC requests for the same issue.
 Improved DAH processes will help ensure operators can maintain their
AD-mandated configurations therefore operators should have fewer instances of
AD noncompliance.
2.5.3 AC 120–16E, Air Carrier Maintenance Programs, Change 1 (Revised)

The FAA issued Change 1 on June 7, 2011. The AC includes information on industry best
practices such as incorporating an AD management process that may help operators ensure
the status of ADs on their airplanes remain current. The AC explicitly states an operator
may not operate an aircraft that an AD applies to except in strict compliance with the
provisions of the AD. The AC recommends operators include a process for evaluating,
accomplishing, and verifying ADs in its manual. The AC also notes 14 CFR requires
operators to keep a record of the current status of applicable ADs, including the date and
methods of compliance, and, if the AD involves recurring action, the time and date when
the next action is required.

2.6 AIR TRANSPORT ASSOCIATION GUIDANCE
2.6.1 ATA Specification 111— Airworthiness Concern Coordination Process
(Improvements)
The ATA is revising ATA Specification 111 to address issues identified in the
AD CRT reports and to develop metrics and means to periodically measure the continued
effectiveness of the process. The ACCP is a cooperative process intended to capitalize on
operator, DAH, and FAA expertise in the development of service information proposals
for issues that may be addressed by ADs. This coordination is valued as the method that
addresses potential unsafe condition with effectiveness, timeliness, and efficiency. Its
purpose is to produce the effective resolution of a potentially unsafe condition by
enhancing communications between the parties that would be most affected by service
information or SBs incorporated by reference in ADs. The Lead Airline Process is that
portion of the ACCP that involves the lead airline, DAH, and FAA—other portions
involve only the DAH and FAA.
ATA Specification 111 had not been updated since 2000 and does not reflect current
air carrier and DAH internal processes. ATA is coordinating the update of
ATA Specification 111 with AD ARC member DAHs and all affected parties.
During the AD ARC discussions, it was noted that ATA Specification 111 represents a
U.S. industry standard whose application is not readily implemented for non-U.S. DAHs
and operators. Airbus, Bombardier, and Embraer have implemented corresponding
processes adapted to their business and regulatory environments.
The revised ATA Specification 111 process will include—

 Transition to DAH Web-based systems for coordination of the process with the
lead airline and communication and of the status of lead airline activities with
other affected operators. Status may be conveyed using terms in the
ACCP flow chart.
 The DAH initiating the Lead Airline Process at the first stage of service
information development in anticipation of FAA’s intention to incorporate the
service information by reference in an AD.
 Provisions for the lead airline and the DAH to involve repair stations, component
manufacturers, maintenance providers, and/or supplemental type certificate (STC)
holders in the ACCP if their participation is relevant to an emerging issue.
 Methods for establishing priorities for the depth of lead airline processing and for
retaining direct ATA involvement and advocacy in high-priority/impact, urgent, or
contentious issues or issues involving multiple-equipment models.
 A standard for providing the individual designated as the lead airline with the text
of proposed service information for review and feedback including those related to
potential urgent rulemaking. Provisions for coordinating inputs to proposed
service information from other potentially affected operators.

 Formalizing provisions for coordinating with FAA Manager, International Branch
(ANM–116) potential mandatory continuing airworthiness information
(MCAI)-related ADs in lieu of formal U.S. lead airline participation in the
development of non-U.S. SBs.
 Revised compliance time recommendations based on timeframes remaining within
clear risk management/safety management system (SMS) estimates.
 Coordination with the DAH to prototype or validate a proposed SB and its kit or
any special inspection before their approval. The DAH should consider inviting
the responsible ACO or Engine Certification Office (ECO) engineer and/or AEG
personnel to observe the validation. In certain cases, particularly ―high risk‖ or
skill-intensive corrective actions, the development of effective service information
will require, in addition to the DAH’s validation process, that the lead airline, or an
arranged alternate airline, prototype or validate the instructions.
 New metrics to determine effectiveness of the Lead Airline Process. The ATA will
poll DAHs, ACOs, and ECOs annually to gather the needed data for the metrics.
The following metrics are under consideration:
o Number of times the lead airline provided feedback on a written draft of the SB
accomplishment instructions,
o Number of times an AD is revised,
o Number of NPRM comments received for a particular AD,
o Number of AMOCs issued for an AD, and
o Number of global AMOCs issued for an AD.
 Emphasis on training, particularly for lead airline designees, in view of the
substantial revision of the specification and related AD ARC products.
 A new appendix to address ―Crisis Communications‖ if significant, newsworthy
compliance concerns arise. The appendix will address rapid establishment of
interfaces with the DAH and FAA and will re-enforce operator awareness of the
existence of FAA’s internal (only) 24/7 hotline.
ATA will tabulate results from agreed on metrics and measure the results against
established standards. The ATA will review the program for potential enhancements for
any identified deficiencies within the ACCP.
Expected Benefits
The expected benefits of the original Lead Airline Process declined because the process
was not initiated on a consistent basis or resources to conduct the Lead Airline Process
were limited with the reduction in operator engineering resources and an increasing
number of proposed ADs. The AD ARC expects the improvements to the Lead Airline
Process will yield enhanced realization of the originally identified benefits as follows:
 Minimize differences between the coordinated and the proposed or final service
information for addressing the unsafe condition;

 Minimize the occurrences of corrections to ADs, including revisions and
supersedures of ADs;
 Feedback on proposed general notes and, according to specific criteria,
identification of critical steps;
 Appropriate compliance through clear and concise technical data;
 A reduced need for AMOCs and AD compliance time extensions; and
 A mutual understanding and awareness of safety issues, risks, and margins among
all stakeholders.
2.6.2 ATA iSpec 2200—Information Standards for Aviation Maintenance

(Updated)
The AD ARC working groups submitted a change request to update ATA iSpec 2200 to
include general guidance material on critical task differentiation, general notes to provide
flexibility, and logic-based diagrams. ATA published the revised document with the
requested changes in May 2011.
Expected Benefits
Incorporating the changes to the AD process in revised ATA iSpec 2200 updates the
specification with new AD ARC-developed guidance on the format and content of SBs
and allow DAHs to provide standardized information to better meet air carrier
operational needs.
2.7 OTHER GUIDANCE

2.7.1 Notice N8100.112, Placing Service Information in the Federal Docket
Management System (New)
Notice N8110.112, Placing Service Information into the FDMS25, explains when to place
service information such as an SB, specified in an AD into the FDMS. The notice
specifies that service information incorporated by reference in an AD must be placed into
the FDMS. Written consent from domestic and foreign DAHs must be provided to the
FAA directorate responsible for the product before placing service information documents
proposed in an NPRM for IBR into the FDMS. This policy also applies to MCAI-related
ADs. The FAA plans to incorporate the policy into the FAA AD Manual by
September 2012.
Boeing provided written consent to place its SBs in the FDMS during the NPRM and final
rule stages. Airbus, Bombardier, and Embraer independently submitted positions
opposing posting their respective service information in the FDMS at the NPRM stage
citing that the service information is available electronically via the DAH’s Web site
before the FAA’s NPRM is published. The AD ARC noted, however, public access to
DAH Web sites is limited.
25
Issued on September 28, 2010.

Expected Benefits
Posting service information to the FDMS during the NPRM stage will enable the public to
review and comment on the contents of the SB as it relates to the AD action.
2.7.2 FAA Policy Memoranda (New)

AEG
On March 20, 2009, the FAA issued a memorandum to AFS personnel to re-emphasize the
role of the AEG and included a reference to its role in AD processes. The memorandum
noted that the AEG is available to provide assistance and technical information. In
addition, the memorandum endorsed early and frequent coordination with the AEG on
technical issues to create a more effective communication network in the interest of safety.
On April 5, 2010, AFS–1 sent a memorandum to the Deputy Associate Administrator

for Aviation Safety to request an increase in AEG staffing to support AD and
AMOC process improvements and other continued operational safety enhancements.
AEG staffing has increased.
24/7 AMOC Process

On March 1, 2010, AFS–1 sent to all AFS regional division managers, all AIR directorate
managers, and all AEG managers a memorandum presenting a schedule for briefing the
24/7 urgent request AMOC process in the regional divisions.26 AFS–1 attached a
January 27, 2010, memorandum explaining that the briefings were in support of
TAD’s 24/7 availability to assist FAA PIs response to urgent requests (after normal
business hours and to avoid significant air transportation disruptions) for AMOCs for ADs.
The memorandum noted the 24/7 process reinforces the importance of early
communication between PIs and the AEG when a technical issue arises from an AD and/or
requires an AMOC.
Expected Benefits
The FAA policy memoranda served as an immediate communication to FAA field
inspectors on the FAA’s policies relating to the AEG and the 24/7 urgent request AMOC
process. In addition, the memoranda ensure field personnel understand that the AEG is a
key resource for technical issues and continued operational safety. The memorandum
requesting an increase in AEG staff resulted in the FAA having the appropriate level of
AEG resources to provide technical support and coordination between the ACO and CMO
when AD compliance issues arise.
These communications are now formalized and included in the appropriate FAA and
industry guidance documents.
26
The FAA conducted seven field briefings from February 2010 to June 2010.

2.7.3 Air Transportation Oversight System Data Collection Tools (Updated)
The FAA issued a final revision to the FAA Air Transport Oversight System (ATOS)
element performance inspection (EPI) data collection tools (DCT) on September 1, 2010,
and a temporary revision to the safety attribute inspection (SAI) DCTs on June 23, 2011.
The revisions include air carrier AD management best practices and align the elements
with the revised FAA Order 8900.1 material. The FAA expects final publication of the
SAI DCT by December 31, 2011. Specifically, the FAA revised the following DCTs:
 DCT Element 1.3.1, Maintenance Program;
 DCT Element 1.3.3, Maintenance Facility/Main Maintenance Base;
 DCT Element 1.3.4, Required Inspection Items;
 DCT Element 1.3.6, Airworthiness Directive Management; and
 DCT Element 2.1.1; Manual Currency.
Expected Benefits
The AD ARC expects the updated DCTs to encourage operators to follow the guidance in
the new ACs on DAH best practices and AD management. In addition, the update should
facilitate transition and change process within the FAA workforce by defining
expectations clearly and institutionalizing the new processes and best practices.
2.7.4 FAA Mandatory Continuing Airworthiness Instructions (Revised)

The FAA revised the FAA MCAI27 comment period from 30 days to 45 days in
September 2009.
Expected Benefits
The extension in the comment period provides a consistent comment period for ADs
affecting domestic and foreign manufactured transport airplanes.
2.7.5 Miscellaneous
AD Worksheet (Updated)
On May 10, 2011, the FAA issued a revised FAA AD worksheet to specify whether credit
can be given for actions accomplished using an earlier revision of the service information.
In addition, the FAA revised the AD worksheet to record the list of existing ADs
affecting/overlapping the newly proposed AD actions that could lead to a noncompliance,
confirm that no conflicts exist, and identify whether the DAH confirmed this information.
AD Templates (Updated)
On May 10, 2011, the FAA revised the AD template to include a compliance paragraph,
regarding credit for actions accomplished using an earlier revision of the service
information. In addition, the AD templates include a note that after accomplishing
27
FAA revised the comment period to respond to AD CRT report recommendations before the AD ARC
was formed. AD ARC determined no other revisions to the instructions are necessary.

actions, maintenance and/or preventive maintenance under part 43 is permitted provided
the maintenance does not result in changing the AD-mandated configuration (reference
14 CFR § 39.7). The AD templates also include new notes that define use of the terms
―refer to‖ and ―in accordance with‖.
The FAA plans to add ―required for compliance (RC)‖ to the template upon FAA issuance
of the final version of AC 20–xxx.
Expected Benefits
 Providing credit for earlier SB actions reduces AMOC requests and the
corresponding burden for preparing and processing those requests by the operator
and the FAA.
 Certain future ADs will clearly state when normal maintenance methods,
techniques, and practices are acceptable for AD-mandated design changes. The
AD templates have a maintenance header with the following note for use in certain
ADs that require design changes:
Note: After accomplishing the actions required by paragraph (**),

maintenance and/or preventive maintenance under 14 CFR part 43 is
permitted provided the maintenance does not result in changing the
AD-mandated configuration (reference § 39.7).
2.8 TRAINING
2.8.1 FAA Training (New and Updated Courses)
AEG Roles and Responsibilities
The AD process changes prompted one new course on AEG roles and responsibilities for
classroom instruction and Web-based training via the Department of Transportation’s
electronic Learning Management System (eLMS). This course was designed by/for AFS
and AIR.
24/7 AMOC Urgent Request Process

The FAA also completed the development of a 24/7 AMOC urgent request process via the
eLMS training course for ASIs working in the field. The FAA anticipates the
eLMS course will be available to the public via Internet access through a secured server
for a fee by 2012.
Foundations for Principal Inspectors

The FAA also updated its training course No. 25704, Foundations for Principal Inspectors
to included compliance planning and ASI decisionmaking guidance. This course is
mandatory for airworthiness ASIs at all 14 CFR part 121 and 135 operators with 10 or
more aircraft.

AD Management
The FAA updated its course (27100009) Airworthiness Directives (AD) Management to
incorporate new guidance developed on the AD process.
Training Schedule
The FAA plans to require FAA personnel to attend FAA training related to AEG roles and
responsibilities, AMOC processes, and AD management during the fiscal year 2013. This
training will apply to the large inspector work force and it will take time to train the entire
work force. The prototyping of the courses was completed between June and July 2011,
and the first classes are scheduled for September 2011.
Expected Benefits
 The FAA expects the training courses will present information on AD process
changes to ASIs emphasizing the FAA’s oversight responsibilities and the use of
good judgment when making AD compliance determinations and handling
large-scale fleet AD noncompliance issues.
 The courses provide a means for receiving feedback from the ASI on the
AD process changes.
 AIR ASEs will attend AEG roles and responsibilities training to ensure all
involved parties across FAA business lines are appropriately informed of the
AD process changes, organizational roles and responsibilities, and interactions.
2.8.2 Industry Training (New)

Industry stakeholders are expected to conduct training on the AD process changes during
the fourth quarter of 2011 and throughout 2012. Such training will consist of
the following:
 DAH employees. Emphasis on training, particularly for DAH employees involved
in preparation, review, and approval of service instructions, focused on the final
version of draft AC 20–xxx and ATA Specification 111.
 Lead airline designees. Emphasis on training focused on the substantial revision of
ATA Specification 111 and AC 20–xxx, particularly provisions regarding general
notes, criteria for determining RC steps, and preclusion of demodification. Other
training topics to include AD ARC revisions of iSpec 2200, sections of FAA Order
8900.1 on AEG roles in AD processes, and of the FAA AD Manual. Any
forthcoming FAA legal interpretation of part 39 also should be reviewed.
 Operator employees. Emphasis on training, particularly for operator employees
involved in engineering and maintenance regulatory compliance, focused on
(1) AC 39–9, (2) AC 20–xxx, (3) corresponding AD ARC revisions of sections of
FAA Order 8900.1 on AD Management, ASI Decisionmaking, AEG roles in
AD processes, AMOCs, and Risk Management Processes, and (4) FAA Order
8110.103A on AMOCs. Training also should include ATA Specification 111 on
crisis communications and any forthcoming FAA legal interpretation of part 39.

Expected Benefits
Industry personnel will benefit by becoming aware of tools and process changes to be
used by ASEs, ASIs, and the AEG’s added roles and responsibilities.

2.9 SUMMARY OF PRIMARY GUIDANCE IMPLEMENTING AD PROCESS CHANGES
Guidance Organized By AD Process Phase
Service Instructions AD Development AD Implementation FAA Oversight
AC 20–xxx, Design Approval Holder FAA Airworthiness Directives Manual AC 39–9, Airworthiness Order 8900.1, Flight Standards Information
Best Practices with Regards to (FAA–IR–M–8040.1C) Directives Management Management System (FSIMS)
Airworthiness Directives28  Earlier SB credit Process29  ASI decisionmaking
 Critical task differentiation  Ex parté communication  AD compliance planning  AD management process
 Standard practices  AEG coordination  AD prototyping  AEG outreach
 General notes  AD sampling/ validation  AEG roles and responsibilities
 Flexibility  24/7 AMOC process  24/7 AMOC process
 24/7 AMOC process  Global AMOCs  Global AMOCs
 Overlapping/  ASI participation in compliance  Risk management process
conflicting ADs planning and AD prototyping
 Maintaining airworthiness
 Global AMOCs
 Ex parté communication
ATA Specification 111,30 Airworthiness Notice 8110.112, Placing Service AC 120–16E, Change 1, Order 8110.103A, Alternative Methods
Concern Coordination Process Information in the Federal Docket Air Carrier Maintenance of Compliance
 AD process improvements Management System Programs  24/7 AMOC process
 Ex parté communication  AD management process in  AEG coordination
 Metrics manual  AMOC coordination
 AD records  AMOC delegation
 Global AMOCs
ATA iSpec 2200, Information Standards AD Worksheets Order 8100.15A, FAA Organization Designation
for Aviation Maintenance  Credit for actions accomplished using an Authorization Procedures
 Critical task differentiation earlier revision of an SB Expands structural and certain global AMOC
 Standard practices  List of existing ADs affecting/overlapping delegation for Type Certificate Organization
 General notes the newly proposed AD action that could Designation Authorization holders
 Flexibility lead to a noncompliance
AD Templates Order 8110.37E, FAA Designated Engineering

 Added a compliance paragraph, Representative (DER) Handbook
regarding credit for actions Expands structural and certain global AMOC
accomplished using an earlier revision delegation
of the service information
 Noted that after accomplishing certain
actions, maintenance and/or preventive
maintenance under part 43 is permitted
provided the maintenance does not
result in changing the AD-mandated
configuration.
 Included “refer to” and
“in accordance with.” 31
FAA Training Courses
 AD Management
 Foundations for PI’s Decisionmaking
(addresses compliance planning and
ASI decisionmaking)
 AEG roles and responsibilities
 24/7 process training eLMS
ATOS Data Collection Tools32
Updated EPIs and SAIs to include AD process
improvements
28
Draft AC. FAA expects to issue the final AC by the end of 2011.
29
Upcoming Change Notice to include minor additions.
30
Draft ATA Specification 111. ATA expects to issue the final version of ATA Specification 111 in October 2011.
31
RC will be added to AD template upon FAA issuance of the final version of AC 20–xxx.
32
FAA will issue final SAI DCTs by December 31, 2011, temporary SAI DCTs issued on June 23, 2011; final EPI DCTs issued on
September 1, 2010.

3.0 FOLLOW-ON ACTIONS
3.1 ADDITIONAL IMPLEMENTATION ACTIONS

The AD ARC identified an original target date of June 30, 2011, for completing its
implementation actions. Because some of the ARC’s primary implementation actions
were not completed until June 2011 or later, the DAHs and operators needed additional
time to incorporate AD policy and guidance changes into their processes and
conduct training.
In addition, the FAA identified some guidance material as secondary deliverables

which will be published after June 30, 2011. These documents typically are being
revised only to reference the primary deliverables that contain AD ARC related guidance
and information.
Draft AC 20–xxx was not published as final by June 30, 2011, because material on
critical task differentiation in the AC was not fully developed or tested in time to support
that schedule. The FAA plans to publish a revised draft AC that includes the discussion
on critical task differentiation for public comment. The FAA anticipates the final AC will
be issued by the end of 2011. See section 2.5.2 for a complete discussion of AC 20–xxx.
3.1.1 FAA Orders

The FAA will revise FAA Order 8900.1 to include secondary guidance on
AD management and compliance planning in the section discussing continuing
airworthiness maintenance programs.
3.1.2 S1000D—International Specification for Technical Publications

The SIWG is communicating with the Civil Aviation Working Group responsible for
updating S1000D and will submit a change request in September 2011 to update S1000D
to include guidance material on critical task differentiation and general notes to provide
flexibility and logic-based diagrams. Revisions to S1000D will occur during the next
publication cycle in 2012.
3.1.3 Advisory Circulars

The FAA plans to revise the following advisory material (secondary deliverables) to
incorporate the revisions to the AD process:
 AC 120–79A, Developing and Implementing an Air Carrier Continuing Analysis
and Surveillance System.
 AC 120–16E, Air Carrier Maintenance Programs33.
 AC 39–7D, Airworthiness Directives.
33
Although the FAA updated AC 120–16E as discussed in section 2.5.2, the FAA plans to incorporate the
six elements of an AD management process and a cross-reference to FAA Order 8110.103 for information
on AMOCs in another upcoming revision to the AC.

3.1.4 Maintain Airworthiness — Production versus In-service Aircraft
During its evaluation of the AD CRT and IRT recommendations, the AD ARC discussed
the difference in regulatory treatment between an aircraft that has had design changes
incorporated during production and an in-service aircraft that has been modified in
accordance with an AD to incorporate the same design change. The ARC assigned the
analysis of this issue to the ADWG and SIWG for potential resolution. The working
groups were unable to resolve this issue. The ARC determined that this issue is outside
of the scope of the AD CRT and IRT recommendations. This is an issue the FAA and
industry may choose to review later. See sections A2.8 and B2.3 of this report for more
information on this issue.
3.2 COMMUNICATION PLAN

3.2.1 Completed/Ongoing Communication Activities
FAA Activities
In support of communicating AD process changes, the FAA conducted seven regional
field office briefings from February 2010 to June 2010. The briefings presented the
background of the AD ARC and addressed communication among the ACOs, AEG, and
CMOs; AEG roles and responsibilities; 24/7 AMOC support process; and RMP.
In addition, from March 2011 through July 2011, AIR conducted an outreach effort at
10 ACOs for ASEs that included a briefing on AD ARC related guidance changes
and training.
Currently, the FAA is developing a plan to brief its workforce on AD ARC activity and
new and updated guidance and FAA orders.
Industry Activities
Boeing published an article titled Industry Efforts to Improve Airworthiness Directive
Implementation and Compliance in its AERO magazine (QTR_02.11). The article
highlights the AD process changes and how the success of the AD ARC is expected to
improve the current process for developing and implementing ADs.
3.2.2 Future Communication Activities

The AD ARC communication plan consists primarily of presentations to industry and the
FAA on the AD ARC’s implementation activities. The AD ARC identified part 121
air carriers, industry associations representing air carriers, business aircraft operators,
engineers, and repair stations; FAA personnel at FAA headquarters and in the field;
DAHs; and labor groups as audiences that would benefit from learning of the AD process
changes. The ARC plans to address these audiences during trade shows, conferences, and
FAA field briefings. For example, Boeing has scheduled a discussion of the AD process
changes during its upcoming Fleet Team Emerging Issues meetings.

The ARC tailored its presentations to its audience noting that one presentation would not
be suited for all audiences. The ARC recognized that joint FAA and industry briefings
would be most effective as all stakeholders would attend and would gain insight from
discussions with one another.
In addition, the ARC identified the following publications for disseminating information
on the ARC’s efforts:
 ARSA Newsletter/Articles,
 Boeing AERO Magazine,
 AeroSafety World Magazine, and
 Regional Horizons annual maintenance issue34, and
 An FAA SAIB.
The ARC also established an ARC Web site

http://www.faa.gov/aircraft/air_cert/continued_operation/ad/ad_arc/ as a means to
communicate information on the AD process changes.
3.3 AD ARC RECOMMENDATIONS

3.3.1 Future FAA/industry Actions
The AD ARC recommends FAA and industry conduct the following activities either
jointly or separately to close the AD ARC’s activities.
 Assess the impact of FAA and industry training on AD process improvements;
 Pursue part 39 implications if needed;
 Enhance or create additional processes/guidance related to open/controversial
issues; and
 Report progress on the implementation of AD ARC products not tracked by
metrics to AVS–1.
3.3.2 Metrics
The AD ARC found that metrics are needed to monitor and measure the ARC’s successes
with the changed AD process. The ARC proposed to collect data on the following counts
and/or measures associated with the ARC’s key objectives.
 Percent of new SBs published using RC concepts that are anticipated to support
ADs (for AD ARC stakeholder DAHs)35. (DAHs implementing concepts in DAH
AC would collect this data.)
The AD ARC anticipates an increasing percent of SBs will include the
RC concepts.
34
Regional Airline Association (RAA) publication.
35
Some DAH will use different levels of RC. See discussion under section 2.5.2.

 Number of errors in ADs (including service information) resulting in a revision to
an AD. (The FAA TAD would collect this data.)
The AD ARC anticipates a trend of decreasing errors in ADs.
 Number of AMOCs issued—
o To provide flexibility for example use of alternative methods, techniques and
practices (such as alternative parts, materials, tools, equipment, test equipment
and procedures) or use of alternative sequence of steps when accomplishing
tasks;
o To correct errors in ADs including service information; and
o Resulting from conflicting ADs for example, new ADs causing demodification
of an existing AD (that is AD noncompliance).
(The FAA TAD and Boeing (only DAH currently delegated AMOC issuance)
would collect AMOC data.)
The AD ARC anticipates a decreasing trend of AMOCs due to the
AD ARC enhancements.
 Percent of part 121 air carriers with all six elements of an AD management
process in accordance with AC 39–9. (AFS would collect this data.)
The AD ARC anticipates an increasing percent of part 121 air carriers
will include the six elements of an AD management process in its
AD management program.
 Number of voluntary disclosures related to AD compliance issues (§ 39.7) for
part 121 air carriers. (AFS would collect this data.)
The AD ARC will review and evaluate the trend data on voluntary disclosures as
many variables can affect increasing or decreasing trends.
 Number of Enforcement Investigative Reports (EIRs) related to AD compliance
issues (§ 39.7) for part 121 air carriers. (AFS would collect this data.)
The AD ARC will review and evaluate the trend data on EIRs as many variables
can affect increasing or decreasing trends.
 Number of flight disruptions and cancellations for part 121 air carriers due to
AD compliance issues (§ 39.7) for example, delays of 60 minutes or greater and
flight cancellations. (ATA and Regional Airline Association (RAA) would collect
this data from their membership.)
The AD ARC anticipates that the number of flight delays or cancellations related
to AD compliance would be lower given the AD process changes such as
24/7 urgent request process should minimize such disruptions.

Analysis
The AD ARC believes that once the implementation actions are in place, an analysis of
the counts and measures above should indicate whether certain AD process
implementation actions are having the desired effect. The ARC recommends a review of
the data and trend information twice a year. This review should be conducted in an
appropriate forum36 to allow industry to meet with key FAA and industry stakeholders to
review the data and recommend any needed adjustments to the AD process changes or
withdrawal of any AD process changes that are not working as planned.
In addition, ATA is developing certain metrics in its revision to ATA Specification 111
(see section 2.6.1). ATA may collect data from its membership on the number of times an
AD is revised, the number of NPRM comments received for a particular AD, and the
number of global AMOCs issued for an AD. ATA noted that the number of AMOCs
issued is emerging as a key, relevant metric on the effectiveness of AD and ATA
Specification 111 processes.
Case Study
The AD ARC stakeholders also propose to conduct a case study review over a multi-year
period to review the actual application of the AD process changes during the phases
of service information and AD development and implementation. The case study
reviewers will provide feedback to stakeholders and TAD through agreed-on
communication channels.
36
The AD ARC recognized the Joint Management Team (JMT) as a possible forum in which to conduct
this review. The JMT is an FAA and industry team comprised of senior industry leaders who meet
quarterly to review rulemaking and policy issues related to aircraft certification and flight standards.

4.0 IMPLEMENTATION ACTION TABLE
IRT Report
Recommendation No. 4.1 Implementation Action

The FAA should retain the right to ground any plane not in Order 8900.1, vol. 3, ch. 60, sec 1, ASI Decision making
compliance with an applicable AD. Inspectors should not be required (April 23, 2011)
or expected to conduct any type of risk-assessment before taking
action on AD noncompliance.
Recommendation No. 4.2 Implementation Action
The FAA should provide timely information about new AD  FAA Order 8900.1, vol. 3, ch. 59, sec. 1, Airworthiness
requirements, in advance of compliance dates, to all relevant FAA Directives Management Process (June 1, 2011)
field offices. Those offices should then be responsive to any carrier  FAA Order 8900.1, vol. 8, ch. 2, sec. 9, Aircraft
that requests assistance in the form of progress-towards-compliance Evaluation Group Outreach in the AD Process (June 20,
audits or reviews, in advance of the AD compliance dates. The FAA 2011)
should revise its workload management systems (including ATOS), so  AC 39–9, Airworthiness Directives Management
that it can accommodate such requests. Process (June 1, 2011)
The IRT believes that this particular form of collaboration should  ATOS DCT (DCT Elements 1.3.1; 1.3.3; 1.3.4; 1.3.6;
benefit the air carriers and the FAA, while protecting the traveling 2.1.1)
public by reducing the chances of major disruptions.
 AD Management Training Course (2710009)
 Updated Foundations for Principal Inspectors (25704)

AD CRT Task 1 Report
Recommendation No. 1—Compliance Versus

Finding Nos. Implementation Action
Noncompliance Decisionmaking Process
The FAA should— 1, 3, and 5  FAA Order 8900.1, vol. 3, ch. 60,
sec. 1, ASI Decision making
 Develop a more objective, deliberative decisionmaking process for
(April 23, 2011); includes a
determining compliance versus noncompliance that can be used in
logical flowchart that provides
any situation.
systematic procedures that can be
 Reemphasize to ASIs that they have the authority to use followed to eliminate
professional judgment to determine whether noncompliance exists. single-person determinations and
 Develop a decision tool for use by ASIs to assist in using elevate concerns regarding AD
professional judgment when making compliance determinations. compliance. Also, see AD CRT
 Streamline and improve the process for making compliance task 2 report, recommendation no.
determinations and make it impervious to external influence. 8 implementation actions.
 Eliminate single-person decisionmaking.  FAA Order 8900.1, vol. 3, ch. 59,
sec. 2 addresses how to process
 Clarify the roles and responsibilities of the AFS, AIR, OEM, and
AMOC requests. (April 12, 2011)
air carrier in the compliance decisionmaking process.
 FAA Order 8110.103A, chg. 1,
 Review the AMOC process for enhancements and to ensure AEG
sec. 3–7, Is AEG Coordination
personnel are included in the process.
Required? (June 30, 2011)
 Develop a process to raise ASI concerns on compliance
determinations to a higher level.
 Define and strengthen the communication process flow and make it
impervious to external influence.

Recommendation No. 2—Service Bulletin Process Finding Nos. Implementation Action

The OEM and ATA, as appropriate, should— 2  ATA revised ATA Spec, 111 to
reflect the changes to the Lead
 Revise the way SBs are written to avoid mandating things
Airline Process because of
that are not required to meet the safety intent of the SB.
AD process improvements.
This would include ensuring air carriers have appropriate
guidance and controls when authoring air carrier  The FAA provides guidance to
AD accomplishment documents. DAHs on compliance terminology
for critical steps in service
 Avoid drafting class 2 SBs. instructions in draft
 Revise ATA Specification 111 for improvements to the Lead AC 20–xxx, Design Approval
Airline Process. Holder Best Practices with
Regards to Airworthiness
Directives. The FAA plans to
issue the final AC by the end
of 2011.
 iSpec 2200 (May 2011) and
S1000D updates to include
RC concept.
Note: The AD ARC member DAHs
have committed to implementing the
FAA and ATA guidance as
appropriate.

Recommendation No. 3— Air Carrier AD Control Process Finding Nos. Implementation Action
Each air carrier should develop processes and procedures to— 2  The FAA issued AC 39–9, which
includes operator best practices
 Prototype ADs before accomplishment.
for (1) preventing ADs from
 Prevent class 2 ADs from being undone during normal becoming undone during normal
maintenance actions. maintenance action; (2) ensuring
 Ensure AD configurations are maintained. AD configurations are maintained;
 Ensure that when incorporating an SB anticipated to become an (3) prototyping ADs; and (4)
AD that the physical condition of prior work is reviewed when ensuring prior service instruction
the AD is issued. work meets AD requirements.
 The FAA issued corresponding
changes to FAA Order 8900.1,
vol. 3, ch. 59, sec. 1,
Airworthiness Directives
Management Process to reflect
AD compliance planning.
Note: The AD ARC member
air carriers have committed to
implementing the FAA guidance and
the ATA and RAA will advocate the
implementation of the guidance with
their membership.

Recommendation No. 4—Industry Training Process Finding Nos. Implementation Action

Each air carrier, OEM, and repair facility should— 4  The FAA issued AC 39–9, which
includes operator best practices
 Implement training on the AD process and AD implementation.
for (1) implementing training on
 Implement training to reinforce best wiring practices (for the AD process and AD
example, EAPAS). implementation to include training
recommendations for complex
ADs and wiring practices (such
as EAPAS).
 FAA Order 8900.1, vol. 3, ch. 59,
sec. 1, states operators should
determine the need for training
and specific labor skills (e.g.,
avionics, Nondestructive Testing
(NDT), structures, etc.).

Finding No. 1 Recommendation No. 1 Implementation Action

The Team found that in some cases, The Team acknowledges the benefits of  ATA updated ATA iSpec 2200
service instructions were not sufficiently current AD-friendly SB improvements, but ATA e-Business change request
user-friendly and complete. These recommends more focus on user-friendly with ―spec ready documentation‖
incomplete instructions resulted in improvements in service instructions and include general notes in
widespread air carrier confusion because as follows: service information. Also
of the differences in the referenced service includes standards for logic-based
 Critical task differentiation. Service
instructions and AD instructions. These diagrams; figures, illustrations,
instructions should explain the safety intent
deficiencies in service instructions have and drawings; and guidance for
of the instructions. They should differentiate
led to an increased demand for AMOCs identifying items as RC in SBs
the critical tasks and task sequences
and AD time extensions and/or that are incorporated by reference
requiring exact conformance from flexible
exemptions. This has strained limited in an AD.
advisory instructions for tasks that are
national aviation authority resources. The common acceptable air carrier procedures.  ATA updated S1000D (Change
Team found that there is an opportunity for This differentiation will allow improved Proposal Form (CPF) to include
expanded use of the FTEI process within understanding of crucial AD requirements general notes in service
the OEM industry. Use of this will ensure and consistent judgment in AD compliance. information , standards for
air carrier’s review proposed mitigating logic-based diagrams; figures,
 Simplified format. Service instructions can
actions and make user-friendly inputs to illustrations, and drawings; and
be written in a simplified format that allows
draft OEM service instructions. guidance for identifying items as
easy translation into an air carrier’s work
RC in SBs that are incorporated
instructions. Standardizing service
by reference in an AD.) ATA
instruction format will facilitate user
plans to release the revised
effectiveness by repetition in knowing where
S1000D in 2012.
critical information is referenced.
 The FAA issued draft AC 20–xxx
 Maintaining airworthiness. Service
on June 13, 2011, which provides
instructions should be written and traceable
guidance to DAHs on
to avoid situations where previous AD
(1) allowing flexibility through
compliance requirements are inadvertently

undone or modified through normal the use of general notes;
air carrier routine maintenance practices. (2) standards for logic-based
(Refer to class 2 issues AD CRT task 2 diagram format, content, and
report in sec. 2.2.5, finding and location; (3) using standardized
recommendation No. 11, for additional format and content for service
information regarding this issue.) instructions that will become
 Flexibility as appropriate. When compatible ADs; (4) use of unambiguous
with the corrective action intent of the AD, language; (5) figures, illustrations,
service instructions should incorporate and drawings; (6) maintaining
general notes providing air carriers latitude airworthiness; and (7) standard
to use (1) acceptable alternative materials practices. The FAA plans to issue
and approved internal procedures without a revised draft AC to include
requesting an AMOC on each deviation or compliance terminology for
(2) where applicable, the option to use their critical steps and address public
engineering authority37. comments in the near future. The
FAA expects to issue a final AC
 Standard practices. The aviation industry
by the end of 2011.
has many processes for performing
maintenance and modifications that have
been standardized and proven effective.
Service instructions should refer to these
standard practices in which air carriers have
experience, confidence, and training.
 Corrective action decision guidelines. In
some situations, alternative corrective
actions are provided to the air carrier for
37
14 CFR § 43.13: Performance rules (general) allows air carriers to use maintenance instructions in their manual in place of the OEM maintenance instructions
when performing maintenance, alteration, or preventive maintenance.

compliance with the AD. Incorporating
logic-based decision diagrams in service
instructions would assist air carriers in
choosing the best corrective action path,
such as continued repeat inspection or
termination repair, based upon the
discovered condition and compliance time.
 Detailed instructions. Service instructions
must make clear whether a figure or drawing
is the authoritative instruction or only an
installation aid. Service instruction text and
drawings must be in agreement with each
other to avoid subjective misinterpretation.
In addition, service instructions should no
longer contain ambiguous terms, such
as ―approximately‖, to define
allowable tolerance ranges and performance
criteria.


The Team learned that the AEGs were not Strengthen the role of the AEG in developing Guidance
playing a significant role in either the and implementing ADs. Ensure ASIs know that  FAA Order 8900.1, vol. 3, ch. 59,
AD review process or the operational the AEG is a resource for reviewing the air sec. 2, incorporated AIR–ANM–
suitability determinations. This was carrier’s AD installation instructions and that 029–WI.
confirmed through interviews with AEG the AEG acts as the liaison between the CMOs
 FAA Order 8900.1 vol. 3, ch. 59,
personnel as well as FAA principal and the ACO on AD implementation issues.
sec 4, incorporated AIR–ANM–
inspectors. The Team recognizes the key When questions arise, make the AEG part of
029–W2
role the AEG can play in the review and these processes to make compliance with the
implementation of an AD. AD as seamless as possible. This approach will  FAA Order 8900.1, vol. 8, ch. 2,
help to prevent future disagreements between sec. 2, AEG Roles and
the FAA and the air carrier. responsibilities.
 FAA Order 8900.1, vol. 8, ch. 2,
sec. 9, AEG Outreach
 Revised the FAA AD Manual,
FAA–IR–M–8040.1C
 FAA Order 8110.103A (AMOC)
 Updated draft FS Order 1100.1
AFS Organizational Handbook
 Updated FS 1100.5C, FAA
Organization—Field
 FAA Order 8900.1, vol. 3, ch. 60,
sec. 1, ASI Decisionmaking
 FAA Order 8110.107, MSAD
(early AEG involvement in
continued operational safety

decisionmaking process.)
Training
 AEG Roles and responsibilities
Classroom (21000079)
 AEG Roles and responsibilities
Web-based (27100159)
 eLMS Training on the 24/7
AMOC process
Other
 24/7 AMOC process roadshow
(field briefings)
 Issued an AEG staffing memo
 AFS–1 issued a memo on AEG
role and reconnect.
 AFS issued a 24/7 AMOC process
briefing memo to the FAA field
inspectors.


The Team found the Lead Airline Process The ATA should review and update  ATA revised ATA Spec. 111 to
supports industry collaboration objectives, ATA Specification 111 to address issues brought reflect the changes to the Lead
but may need to be updated to reflect forward in this report with emphasis on the Airline Process as a result of
today’s OEM and air carrier supporting following items: AD process improvements. The
internal processes. As the aviation revision also addressed ex parté
 A goal of the Lead Airline Process should be
industry business environment has contacts.
to contribute to clear and accurate service
changed, the impact thresholds for instructions that avoid prescriptive processes  The FAA issued AC 39–9,
activating full network coordination and where standard practices are available and AD Management Process which
full-scale prototyping have increased. applicable. Ideally these instructions includes best practices for
The Team also observed that the ex parté contribute to effective implementation by a operators on AD pre-planning,
policy may not be well understood by the technician. The process should lend AD implementation,
FAA and air carriers. Many in the FAA particular attention to developing service AD verification programs, and
and the industry believe that ex parté instructions involving previous overlapping prototyping of work instructions.
communications are restricted to data ADs or a series of ADs or SBs on (1) the The AC also suggests inviting
requests from the FAA after an NPRM is same component, (2) wiring and other ASIs to participate in compliance
published in the Federal Register. The actions dependent on workmanship, and (3) planning activities.
Team noted that the FAA can class 239 type actions that are easily  AC 39–9 [Change] suggests
communicate with the lead airline after reversible in future maintenance. In these inviting ASIs to participate in
NPRM publication; however, the FAA cases, prototyping of proposed service prototyping activities.
must document all communications and instructions on inservice airplanes is  The FAA issued a section on
.38 particularly important, and OEM
place them in the rulemaking docket Evaluating an Airworthiness
participation should be considered. The Directives Management Process
process should— in FAA Order 8900.1, vol. 3,
38
See discussion on Ex Parte Contacts, page 6, FAA Airworthiness Directives Manual, dated January 23, 2007; FAA–AIR–M–8040.1.
39
This type of AD requires a configuration change that, after implementation, potentially has a higher vulnerability of being undone through the air carrier’s
standard maintenance practices or operations.

o Identify differences in airplane ch. 59, sec. 1 which states an
configurations relevant to the proposed operator may request/invite ASIs
service instructions. to the AD planning meeting.
o Ensure lead airlines are selected  The FAA revised the FAA AD
according to qualifications, capability, Manual
and commitment to the process. (FAA–IR–M–8040.1C (ch. 3)) to
clarify ex parté communication.
o Predispose service instructions to support
 The FAA issued draft
AD compliance planning objectives cited
AC 20–xxx on June 13, 2011,
in the two bullet points directly below.
which provides guidance to DAH
 The ATA should periodically review the on ex parté contacts. The FAA
Lead Airline Process to ensure the expects to issue a final AC by the
continuing effectiveness of the process. end of 2011.
 The ATA should coordinate the update to
ATA Specification 111 with the OEM. This
will help to streamline and better integrate
the Lead Airline Process with OEM fleet
support processes.
 The ATA should add to ATA
Specification 111, or develop a new
specification to address (upon adoption of
an AD) AD compliance planning that
includes the following industry guidelines:
o Invite the ASI to air carrier compliance
planning sessions and AD compliance
prototyping for better understanding
of issues.

o Ensure the accuracy and clarity of the
engineering order (EO) or other
implementation document. The air carrier
should consider silent prototyping where
a technician prototypes the EO without
verbal or other assistance.
o Augment air carrier compliance planning
with an AD verification program.
 The ATA, in coordination with the FAA,
should takes steps to clarify to the industry
and FAA personnel that ex parté
communications can take place if the
communications are fully documented and
placed in the rulemaking docket for
public review.

Finding No. 4 Recommendation No. 4 Implementation

The Team found systemic problems in the The Team recommends the following related to The collective efforts of the AD
AD process as follows: AD development: ARC’s implementation actions will
 Multiple ADs affecting airworthiness in  Charter a joint team made up of assist with ensuring the AD process
the same area of the airplane resulting representatives from the FAA, OEM, and is efficient and effective. In addition,
in overlapping and confusing mandates air carriers to resolve finding No. 4. The the FAA issued draft AC 20–xxx on
for air carriers. This can lead to overarching goal is to ensure that the June 13, 2011, which includes a
inadvertent noncompliance or reversal AD development process is effective and discussion of the use of ―later
of previous AD actions. efficient and results in a compliant product approved parts‖ language in the SB
for air carriers. in sec. 5–5, Minimizing AMOCs for
 Occasionally, the OEM’s service
Design Changes. The FAA expects
instructions are not available when the  OEMs should streamline service instruction
to issue a final AC by the end of
AD NPRM is issued. In addition, development and revision processes to
2011.
copies of service instructions are not expedite release to air carriers.
included in the Government’s  OEMs should review Intellectual Property Participating DAHs agreed to
electronic regulatory docket system. In and Export Compliance policies to allow evaluate the list of process
either case, this prevents air carriers easier public access to NPRM- and improvements for expediting release
from having the full comment period to AD-referenced service instructions via the of service instructions and
comment on the specifics of the electronic regulatory docket system. documenting the feasibility of
service document. implementing the improvements
 At a minimum, the first compliance within their organization. These
 ADs generally have an aggressive deadline should always be stated in the
installation timeline. Because of the DAHs each submitted a letter to the
NPRM and AD. FAA outlining their review of the
urgent nature of AD tasks and the need
 For situations involving multiple structural process improvements and
for planning to minimize aircraft
service documents and ADs, the FAA should implementation plans relative to
out-of-service time, air carriers
explore innovations in AD tracking and streamlining service instruction
frequently accomplish service
management (for example, a zonal approach, development and expediting service
instructions ahead of the AD issuance
where tasks are compiled covering all instruction release to air carriers.
date. This creates an exposure to

noncompliance when there are changes AD requirements for a given area). See section A.2.4.
in the final AD that differ from the  Air carriers must have a process in place to FAA–IR–M–8040.1C, ch. 8 specifies
originally released service document. continually verify AD accomplishment. to allow credit when appropriate for
The Team noted that as part of a process (Also see discussion in recommendation actions accomplished using an earlier
improvement effort, in 2006 the FAA No. 3 above and sec. 2.2.4 of the AD CRT version of the service instructions
signed a working agreement with Boeing Task 2 report). than identified in the AD action.
Commercial Airplanes on Agreed On September 28, 2010, the FAA
Principles and Practices for AD-friendly issued Notice N8110.112, Placing
service bulletins related to the Boeing Service Information in the Federal
transport fleet. The agreement was Docket Management System
developed as part of a joint effort by the (FDMS). The notice specifies that
FAA and an OEM to identify and the FAA must post service
implement improvements to the format information incorporated by
and quality of service instructions and reference into the FDMS and may
ADs. The Team acknowledged that the post service information at the
joint effort is a major step in improving the NPRM stage upon approval from the
FAA’s AD process, provided that certain DAH. This will make compliance
recommendations in sec. 2.2.2 of the AD times visible to the public. In
CRT Task 2 report regarding service addition, the FAA plans to include a
instructions are incorporated to simplify range of compliance times in the
air carrier implementation. NPRM preamble for those NPRMs
that do not include specific
compliance times in the regulatory
text of the NPRM.
The FAA received responses from
Airbus, Bombardier, and Embraer,
respectively that provided their
position for posting service

information at the NPRM phase. The
DAHs did not agree to allow posting
of their service information identified
in an NPRM citing that the service
information is available
electronically via the DAH’s
Web site long before the FAA’s
NPRM is published. Boeing
previously provided permission to
post its service instructions at the
NPRM phase.
The FAA updated the AD Worksheet
(domestic only) to list ADs
affecting/overlapping the current
AD action that could lead to a
noncompliance; confirm that no
conflicts exist; and identify that the
DAH confirmed this information.
The AD Worksheet also instructs
ASEs to specify whether credit can
be given for actions accomplished
using an earlier revision of the
service information.
FAA updated the AD template to
include a paragraph on maintenance
following certain mandatory design
changes. AD templates also include
a Compliance paragraph, regarding

credit for actions accomplished using
an earlier revision of the service
information.
The FAA issued draft AC 20–xxx on
June 13, 2011, which provides
guidance to DAH on (1) checking for
conflicting/overlapping ADs; (2) use
of later-approved parts in service
information; (3) ex parté
communications; and (4) potential
process improvements that reduce
flow time and improve quality for
service instruction development. The
FAA expects to issue a final AC by
the end of 2011.
The FAA issued AC 39–9, which
suggests operators have a process
in place to continually verify
AD accomplishment.


Overall, the Team found that the MCAI In view of foreign authorities’ AD rulemaking The FAA extended the comment
process works well. However, the Team processes (for example, foreign national period from 30 to 45 days for MCAI
noted that addressing the anomalies above aviation authorities’ apparent lack of a NPRMs to standardize with domestic
will further enhance MCAI effectiveness. comparable Lead Airline Process and reduced NPRMs. The FAA Transport
comment periods for proposed MCAIs), the Airplane Directorate also is
FAA should extend the typical comment period harmonizing certain terminology
for MCAI NPRMs. The comment period used in transport airplane ADs with
should be extended from 30 to 45 days, the foreign civil aviation authorities
standard for noncontroversial FAA NPRMs. In through its business plan process.
addition, the FAA and foreign national aviation
authorities should work to harmonize
AD processes.
The Team found that it is important to  The FAA should revise the Air Transport AC 39–9 includes best practices for
identify the following through air carrier Oversight System (ATOS) guidance material pre-planning, implementation,
manuals and FAA guidance material and for ASIs to align these tools with the above AD prototyping, and AD verification
policy: (1) the elements for effective AD discussion as appropriate.40 programs. The AC includes CMO
compliance planning and implementation,  ATA should review the primary elements for and Flight Standards District Office
(2) the specific associated processes and air carrier internal compliance planning (FSDO) participation in compliance
tasks that comprise these elements, and discussed above and disseminate like planning. CMO and FSDO
(3) the individuals with authority and information to the industry. (See above participation in AD prototyping will
responsibility for the elements. discussion of the Lead Airline Process under be addressed in an upcoming Change
section 2.2.2, AD Development, AD CRT notice to AC 39–9.
40
FAA Safety Attribute Inspection (SAI) Data Collection Tool, 1.3.6 AD Management (AW) and the FAA Element Performance Inspection (EPI) Data
Collection Tool, 1.3.6 AD Management (AW).

Task 2 report.) ATA notified its membership of the
 The FAA and ATA jointly should develop a availability of AC 39–9 via email.
policy for CMO participation during the FAA Order 8900.1, vol. 3, ch. 59,
air carrier’s AD compliance planning sec. 1 describes the ASI’s role in the
process. CMO participation during the air carrier’s AD compliance planning
process will educate the ASIs on the air meetings.
carrier’s AD compliance plan
recommendations. However, the CMO Updated ATOS DCTs (EPI
should not perform a quality control function final revision issued on
or require a signoff. Currently, FAA September 1, 2010; SAI temporary
principal inspectors are invited to reliability revision issued on June 23, 2011,
board meetings at some air carriers but with final version expected by the
otherwise are not involved in developing end of 2011).
EAs. The intent of advance CMO
participation is to obviate the need for
AMOCs and reduce paperwork violations
and infractions.
 CMOs should participate in AD prototyping.
However, this monitoring should not require
a signoff from the CMO or be a required step
to completing any work.


During the interviews with principal  The FAA should establish a formal See Implementation Action for
inspectors, it was clear to the Team that the notification and coordination policy on how AD CRT task 2 report, finding No. 2.
FAA field offices41 do not communicate to handle issues where compliance is
unclear. The policy should clearly delineate The FPWG deemed no
with the AEGs on AD issues. In addition,
the AEG’s role in assisting with organizational change was
the field offices do not consistently
noncompliance determinations, specify who necessary and instead increased
communicate with the ACOs when
has decision authority, and provide AEG staffing levels.
AD compliance issues arise.
guidelines for elevating issues of
disagreement for resolution. (Also see
recommendation No. 8 below). Such a
policy will enhance overall coordination
efforts and help the AEG to better coordinate
with the ACO.
 The FAA should consider an organizational
and procedural change to ensure FAA field
offices have a direct link to the AEG. This
will help the CMOs obtain technical advice
on ADs and all issues concerning certificate
management.
41
FAA field office refers to (1) the CMOs that specialize in the certification, surveillance, and inspection of major air carriers and part 142 training centers and
(2) the Flight Standards District Offices (FSDOs) that conduct certification, surveillance, and investigation of all other types of aircraft operations.


The Team found that during the events Under all circumstances, FAA technical Guidance
precipitating this review, FAA personnel must be consistent in reviewing,  FAA Order 8900.1, vol. 3, ch. 60,
administration of the AMOC process was approving, and applying the processes under sec. 1, ASI Decision making
reported to be inconsistent and sound their responsibility. If there are concerns (includes a logic flowchart that
technical judgment did not always govern regarding outside undue influence, the affected provides step-by-step procedures
decisions. party must seek guidance from organizations that can be followed to eliminate
having the appropriate level of ability and single-person determination and
authority to provide the guidance required to to elevate concerns regarding
address the concerns. AD compliance.);
FAA policymakers must ensure individuals  FAA Order 8900.1, vol. 10, ch. 3,
responsible for the control of the AMOC sec. 1 revised the RMP
processes are fully aware of the scope of their (January 10, 2011) to
responsibilities. They should also be aware of include ADs;
the available recourse for appropriate  FAA Order 8900.1, vol. 3, ch. 59,
management guidance where required. sec. 2, Processing an AMOC
Educating these individuals will help ensure Proposal which provides guidance
proper and prompt technical resolution of on how AFS ASI should
problems. Specifically, the Team recommends coordinate with AIR and how
the following: approval/denial letters for
 The FAA should, in coordination with AMOCs should be processed;
industry, charter a working group to review  FAA Order 8900.1, vol. 3, ch. 59,
and develop a means to strengthen the sec. 3, Processing AMOC
AMOC process. The group’s charter should Proposal to ADs which explains
include a review of the following: the ASI Role in the AMOC
process; and

o Communication channels;  FAA Order 8900.1, vol. 3, ch. 59,
sec. 4, Requesting 24/7 Support
o Simultaneous coordination of an AMOC for AMOCs.
with the ACO and the CMO;
o Concurrence (that is, ACO expeditiously
receives concurrence from AEG on the Updated the following FAA Orders
AMOC, and AEG advises CMO); to promote widespread use of single
o Further delegation to designated structural airplane AMOCs and
engineering representatives (DER) and certain global AMOCs.
authorized representatives (AR), to FAA Order 8100.15A, Organization
include AMOCs that address issues in the Designation Authorization
systems and equipment, payloads, and Procedures (June 10, 2011);

airplane performance areas; FAA Order 8110.37E, Designated
Engineering Representative (DER)
o Delegation of AMOCs to other ACOs;
Handbook (March 30, 2011), and
and
FAA Order 8110.103A, Alternative
o Staff availability on a 24/7 basis (ACO, Methods of Compliance and Change
AEG, and CMO). Notice (September 29, 2010 and
 The Independent Review Team made a June 30, 2011.)
recommendation that ―[i]nspectors should
Training
not be required or expected to conduct any
type of risk-assessment before taking action Updated profile for Foundations for
on AD noncompliance.‖ The Team agreed PIs (25704) and mandated training
with this finding as supporting the necessary for all part 121 and 135 principal
enforcement needed once an airplane has maintenance inspectors.
been determined to be noncompliant. Other
However, the Team developed a
supplemental process to help the ASI first Updated ATOS DCTs (1.3.1; 1.3.3;
coordinate a valid determination of 1.3.4; 1.3.6; and 2.1.1).
compliance in cases where the condition is
not obvious. The Team recommends that
the FAA:
o Develop further guidance and training to
assist FAA staff in correctly determining
noncompliance.
o Develop a formal policy regarding ASI
decisionmaking. The policy should
emphasize the technical authority of the
ACO and the FAA’s position on the
authority of ASIs to use professional

judgment when determining compliance.
To eliminate single-person
determinations, the policy should address
any conflicts that arise on an AD or
AMOC by requiring the CMO to elevate
its concerns first to the AEG for
resolution.
The FAA should develop a decisionmaking
flowchart as a guide for ASIs making
compliance determinations. An ASI decision
flowchart is provided to demonstrate the notion
the Team wishes to convey. (See appendix C to
AD CRT task 2 report.)

The Team noted that air carriers and The FAA and industry should develop a process  Draft AC 20–xxx, (1) documents
CMOs often are not aware of applicable to approve all AMOCs as global unless the original equipment manufacturer
global AMOCs that the FAA has approved. requesting air carrier specifically states that it (OEM)/DAH best practice of
Some air carriers and CMOs misinterpret does not want the AMOC shared. The global implementing a formal process to
the requirement that air carriers notify AMOCs would be posted on OEM Web sites review all AMOC requests as
their CMO before implementing a global accessible to all air carriers in a way that candidates for issuance as global
AMOC as a requirement to gain the protects the intellectual property rights of the AMOCs when applicable and
approval of the CMO. OEMs and the air carriers where appropriate. (2) suggests a DAH should
consider posting global AMOCs

The industry and the FAA also should ensure issued against their products on
that CMOs do not require air carriers to gain a Web site that is accessible
their approval to implement a global AMOC. by operators;
 AC 39–9, Airworthiness
Directives Management Process,
specifies DAH best practices on
AMOCs;
 AC 39–9 [Change] specifies for
the operator requesting an AMOC
to request a global when
appropriate, give the FAA
permission to share the subject of
AMOCs with DAHs so the DAH
can determine if the AMOC could
be global and when consulting
with the DAH on AMOCs,
allowing the DAH to use the
AMOC request as a basis for a
global AMOC.
 FAA Order 8110.103A, CHG 1,
AMOCs to create a new
paragraph 4–3f. Sharing AMOC
Requests with OEM/DAHs; and
 FAA Order 8900.1, vol. 3, ch. 59,
sec. 3, Processing AMOCs
to ADs.


The Team found that although air carriers Responsive communication and industry  AC 39–9 [Change] includes a
had access to the ACO, the ACO found it collaboration are essential in crisis situations recommendation that operators
more efficient to collectively address the involving widespread AD compliance issues develop a process that may
volume of air carrier issues through the affecting air carriers. The ACO and OEM reference a conflict resolution
OEM. The ACO often was occupied and should develop contingency procedures and process to coordinate
not available to individual air carriers. As disseminate them internally in advance of future AD compliance matters needing
a result, the OEM was the best positioned events. This will ensure that points of contacts immediate resolution with the
to develop an overall picture of are established for air carrier use in expediting local FAA office. In addition, the
developments. In effect, the OEM resolution of fleet wide issues. The ATA may AC suggests air carriers that are
operated a ―war room,‖ orchestrating facilitate this process provided that air carriers members of industry associations
conference calls for air carriers, CMOs, immediately advise the ATA of a significant consider using established
and ACOs. compliance issue that may be widespread and processes such as
newsworthy. ATA Specification 111 or similar
processes developed by other
associations, for significant
compliance issues that may be
widespread and newsworthy.
This could include coordination
with associations, regulatory
authorities and OEMs/DAHs.
The AC also includes a discussion
of 24/7 AMOC support in
appendix 1 to the AC.
 FAA Order 8900.1, vol. 3, ch. 60,
sec. 1 ASI Decisionmaking
includes all ASIs should
determine what resources are

needed to solve difficult and
controversial issues. ASIs are
directed to seek guidance from
internal FAA resources, including
the CHDO, PI, AEG, ACO,
Regional Office, and/or
appropriate FAA
headquarters-level branch.
 Draft AC 20–xxx, includes a
section on 24/7 AMOC support
that specifies to help prevent
grounding aircraft due to potential
AD noncompliance by an
air carrier, a DAH should develop
a process for 24/7 support.
 ATA Specification 111 will
include an appendix on ―Crisis
Communication‖ to rapidly
establish contact with the FAA
and DAH for high-visibility issues
of potential noncompliance.


The Team found that unless otherwise Air carriers should develop practices to address AC 39–9, Airworthiness Directives
directed, maintenance technicians working normal maintenance or other actions that could Management Process addresses
in the vicinity of the class 2 installations possibly demodify an AD configuration, AD sampling.
any time after the AD is implemented, particularly class 2 ADs. These could include
typically employ standard maintenance the following:
practices. This raises the risk of  Process enhancements or physical marking
inadvertently taking the airplane out of of AD installations for nonstructural ADs.
compliance with elements of the AD. This alerts mechanics to the presence of an
AD installation in the area where they are
working.
 Quality assurance sampling of AD projects
to verify the correct setup, and/or a sampling
program that physically verifies
demodification has not occurred.


The Team found that the amended The FAA should review §§ 39.7 and 39.9, and,  FAA issuance of proposed legal
regulatory language in §§ 39.7 and 39.9 if necessary, revise those sections to clarify that interpretation on §§ 39.7, 39.9,
could be interpreted as requiring every AD compliance is an action required of the and 39.11;
element of every applicable AD to be in operator; it is not necessarily determined by a  AC 39–7D Airworthiness
strict compliance with the mandated strict comparison of the aircraft to AD-specified Directives (upcoming Change);
configuration on every flight. This finding configurations.  AC 39–9 Airworthiness
adds emphasis to (1) the need for ADs and Directives Management Process;
service instructions incorporated by
reference in ADs to clearly state the safety  FAA Order 8110.103, AMOCs,
intent and instructions essential to meeting CHG 1;
that intent, (2) the use of professional  AC 120–16E Air Carrier
judgment in compliance determinations, Maintenance Programs, Change 1,
and (3) measures to better plan and (June 7, 2011); and
monitor AD compliance.  AC 120–79A (Continuing
Analysis and Surveillance
Systems (CASS))

5.0 CONCLUSION
The AD ARC’s implementation actions combined with FAA and industry training
institutionalize the AD process improvements presented in this report and support the
goals of a compliant product and the avoidance of future large-scale disruptions in
scheduled air transportation. The ARC expects the AD process improvements to promote
better communication and coordination among FAA offices and between FAA and
industry stakeholders on AD issues. Specifically, the changes to FAA policy and
DAH processes will facilitate AD compliance. For example, in SBs that are to be
incorporated in ADs, specifying what items are critical to accomplish to correct the
unsafe condition will reduce the scope of the required actions thereby reducing the
potential AD noncompliance determinations.
Other improvements such as referring to industry standard practices when possible, using
general notes for flexibility, logic diagrams, and clarifying figures that are authoritative
versus reference material will standardize SB format, facilitate AD implementation, and
serve to reduce potential noncompliance issues. Further, operator-established
AD management and compliance planning, and AD verification processes along with
ASI participation in air carrier/operator compliance planning and AD prototyping should
support early identification of potential AD compliance issues and appropriate resolution
prior to the AD compliance deadline, as well as facilitate continued compliance. All of
these improvements will mitigate potential AD compliance issues and the resulting
operational impacts.
The AD ARC notes it has already received positive feedback from FAA and industry on
the 24/7 process changes to request AMOCs and the improved ASI communication and
coordination process with other FAA offices and the operator on suspected issues of
AD noncompliance. The ARC finds its success largely depends on the industry adopting
the best practices outlined in the published ACs. The ARC proposes metrics be analyzed
to monitor and measure the success of the changed AD process. Based on the metrics,
further process improvements may need to be made or certain practices discontinued if
identified as not practicable. In addition, the FAA plans to issue a communication to
industry discussing the ARC’s activities and advocating the need for industry to adopt the
best practices regarding ADs in recently issued FAA and industry guidance.
As an implementation ARC, the AD ARC believes it successfully addressed each of the

AD CRT and IRT recommendations, although some of the recommendations may not
have been implemented exactly as stated. For example, the FAA did not reorganize the
AEG as the AD CRT recommended but made guidance, communication, coordination,
and process changes regarding the AEG and increased AEG staffing.
The AD ARC also found it impracticable to approve all AMOCs as global as suggested
by the AD CRT because most AMOC requests address unique configuration issues or
situations that may not be applicable to other aircraft. The AD ARC instead supported
that all AMOC requests that have general applicability be reviewed to determine whether
a global AMOC can be issued. The AD ARC did not find the AD CRT recommendation

to delegate AMOCs from issuing ACOs to other ACOs an efficient or effective strategy
because other ACOs do not have the information related to the safety issue or a
familiarity with the airplane design. However, the AD ARC supported the delegation of
structural single-airplane AMOCs and certain global AMOCs to DAH designees.
In addition, only one DAH participating on the ARC agreed to provide permission for
posting service information at the NPRM stage to the FDMS as the AD CRT suggested;
the other DAHs oppose this practice. For critical task differentiation, all DAHs agreed to
differentiate critical tasks in SBs using the RC concept, but for some DAHs (Airbus and
Bombardier) the level of detail is less than what the other DAHs agreed to implement.
Finally, the ARC provided suggested revisions to ATA Specification 111 to incorporate
the changes to the AD process but the ARC acknowledged that ATA Specification 111 is
not used by non-U.S. DAHs which operate under a different regulatory system. These
non-U.S. DAHs acknowledge they have corresponding processes to prototype,
respectively validate, ADs with their operators.
The AD ARC also notes that although the AD ARC reviewed part 39 as recommended
and requested an FAA legal interpretation to clarify AD compliance, the resolution of
part 39 issues is incomplete. The FAA’s proposed AD interpretation is that after the
implementation of an AD every element of that AD must be in the mandated
configuration on every flight. As of the release of this report, the FAA has not finished its
evaluation of public comments on the proposed interpretation. The ARC recommends
that the AD process improvements presented in this report be reviewed for their efficacy
upon release of a final legal interpretation and be affirmed, revised, or rescinded
if needed.

APPENDIX A—SERVICE INFORMATION WORKING GROUP
A1.0 INTRODUCTION
The AD ARC formed the SIWG to address AD CRT recommendations related to the
development of service instructions. The SIWG’s key objective was to revise the way
service instructions are written to avoid mandating actions not required to meet the safety
intent of the AD.
The SIWG’s 21 members and 1 observer represented AFS, AIR, foreign aviation
authorities, U.S. air carriers, an air carrier association, U.S. and foreign airplane
manufacturers, and repair stations. The SIWG held monthly meetings and
teleconferences to evaluate and develop implementation actions for its assigned
recommendations. The SIWG co-leads tracked its progress using project plates that
contained the assigned recommendation, the expected outcome/deliverables, and
individual milestone tasks. The SIWG co-leads provided status updates to the
AD ARC members at the AD ARC meetings noting if the working group would meet its
schedule to complete its review and analysis of the assigned recommendations or had
encountered difficulties.
A2.0 ASSIGNED TASKS

The AD ARC assigned the SIWG the following 14 recommendations to evaluate and
develop implementation actions:
 Write service information to avoid mandating things not required;
 Avoid drafting class 2 SBs;
 Critical task differentiation;
 Simplified format;
 Maintain airworthiness;
 Flexibility as appropriate;
 Standard practices;
 Corrective action decision guidelines;
 Detailed instructions;
 Streamline service information development and revisions;
 Revise ATA Specification 111;
 Use Lead Airline Process to develop service instructions;
 Review Lead Airline Process to confirm effectiveness; and
 Coordinate update to the Lead Airline Process.
Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page A–1

The SIWG documented its evaluation of each recommendation and the implementation
action in a summary sheet report. The SIWG addressed the 14 recommendations in
9 summary sheets combining recommendations where possible.
The SIWG also documented a separate assigned task to address maintenance of

mandatory design changes in a summary sheet. The SIWG evaluated a proposal from the
ADWG that depended on the development of new Airworthiness Limitations (AWL) to
protect safety-critical configurations mandated by an AD.
The complete unedited working papers that documented the AD ARC’s working groups’
review, analysis, and decisions are available for viewing and download from the
AD ARC Web site at http://www.faa.gov/aircraft/air_cert/continued_operation/ad/ad_arc/.
Each assigned task, its implementation action, and outcome are excerpted from the
SIWG summary sheet reports and presented below.
A2.1 Corrective Action Decision Guidelines

Task
The SIWG evaluated the following AD CRT recommendation:
The Team acknowledges the benefits of current AD-friendly SB

improvements, but recommends more focus on user-friendly
improvements in service instructions as follows:
 Corrective action decision guidelines. In some situations, alternative
corrective actions are provided to the air carrier for compliance with the
AD. Incorporating logic-based decision diagrams in service instructions
would assist air carriers in choosing the best corrective action path, such
as continued repeat inspection or termination repair, based upon the
discovered condition and compliance time period.
(AD CRT task 2 report, recommendation No. 1, bullet No. 6)
Review of Issue/Problem
Logic-Based Diagrams
The SIWG noted that service instructions are occasionally and necessarily complex.
A complex service instruction specifies multiple airplane configurations and corrective
actions, multiple alternative corrective actions, and complex compliance times. This
complexity can result in confusion regarding what work needs to be accomplished and
what work already has been accomplished to be in compliance with an AD. This
complexity can also make it difficult for the FAA to enforce the actions defined in the
service instructions.
The SIWG found some DAHs include logic-based diagrams to assist

air carriers/operators in choosing the best corrective action path for complex service
instructions. However, before 2008, limited documentation, guidance, and standards for
creating logic-based diagrams existed. This resulted in a wide variation in format,

content, and location of the diagrams. In 2008, one DAH worked with the FAA’s TAD to
identify issues and develop standards and document guidance for logic-based diagrams in
future service instructions. Based on the issues identified and their solutions, the
SIWG concluded—
(1) Each DAH participating on the AD ARC include logic-based diagrams at least as
a secondary source of information in its complex service instructions, considering
the format, standards, and guidance previously created and
(2) Each DAH will be responsible for incorporating these standards into its internal
processes for creating service instructions.
Logic-Based Diagram Standards

The SIWG determined the following standards should be used when including
logic-based diagrams in service instructions.
 The DAH will determine when to include a logic-based diagram in service
instructions. The DAH will use judgment to determine when the service
instruction is complex and a logic-based diagram should be included. The DAH
should also consider a request from air carriers/operators and FAA personnel on
whether a logic-based diagram would be helpful.
 The logic-based diagram should not be a required portion of the service
instruction. It should be provided as an aid to help air carriers determine the
necessary tasks in accomplishing the service instruction.
 Logic-based diagrams should be located as an appendix to the service instruction.
 Logic-based diagrams should include tasks and times for when to do those tasks.
 The logic-based diagram should not be the primary source for compliance
information. The diagram should be provided as a supplement to the information
in the compliance and accomplishment instruction paragraphs.
 The service instruction should make it clear that the logic-based diagram is not
the authoritative source for tasks. It should be clear the logic-based diagram is
only a supplement to the tasks described in the accomplishment instructions and
the times specified in the compliance paragraph of the SB. A general note in the
accomplishment instructions paragraph and on the logic-based diagram should
delineate this requirement.
 Use consistent terminology within the logic-based diagram.
 Use descriptive and concise terminology in the logic-based diagram.
Implementation
The SIWG’s implementation action to address the recommendation included
documenting the standards for logic-based diagram format, content, and location.
The SIWG drafted the proposed documentation and submitted it to through the FPWG to
the FAA which reviewed the draft documentation, and incorporated the guidance in
draft AC 20–xxx.

The SIWG also worked, in parallel, with ATA and representatives from the S1000D
Civil Aviation Working Group to request the standards for logic-based diagrams be
incorporated into industry specification documents (that is, ATA iSpec 2200 and
S1000D). Each DAH participating on the SIWG reviewed their internal documentation
for creating service instructions and has committed to incorporate the standards into their
documentation during upcoming revision cycles. DAHs, operators, and regulatory
authorities need to provide training to all personnel who author, review, approve,
implement, and enforce service instructions. The SIWG also developed and provided
potential training material to the FAA.
Outcome
The SIWG’s implementation actions successfully address the AD CRT
recommendation by—
 Incorporating logic-based decision diagrams in FAA and industry service
instructions;
 Documenting the standards for logic-based diagram format, content, and location
in draft AC 20–xxx, ATA iSpec 2200, and S1000D;
 Developing training material; and conducting training.
In addition, the DAHs on the SIWG committed to include logic-based diagrams in

complex service information.
The SIWG’s anticipated effect of incorporating logic-based decision diagrams in service

instructions is that logic-based diagrams will assist operators in selecting the optimal
corrective action in complex service instructions. The standardized format, content, and
location of the diagrams will increase users’ familiarity through repetition on the location
and content.
A2.2 Critical Task Differentiation

Task
The OEM and ATA, as appropriate should—
 Revise the way SBs are written to avoid mandating things that are not
required to meet the safety intent of the SB. This would include ensuring
air carriers have appropriate guidance and controls when authoring air
carrier AD accomplishment documents.

 Critical Task Differentiation. Service instructions should explain the
safety intent of the instructions. They should differentiate the critical tasks
and task sequences requiring exact conformance from flexible advisory
instructions for tasks that are common, acceptable air carrier procedures.

This differentiation will allow improved understanding of crucial
AD requirements and consistent judgment in AD compliance.
(AD CRT task 2, recommendation No. 1, bullet No. 1)
Service information incorporated by reference such as an SB in an AD, often contains all
of the steps to accomplish the necessary inspections, repairs and/or modifications.
Although these SBs may include detailed instructions necessary to complete the work
package including access and close-up steps, not all of these steps may be directly related
to correcting the unsafe condition that prompted the AD. In some cases, tasks included in
the SB can be accomplished using acceptable operator procedures. In other cases, tasks
must be accomplished in accordance with the procedures specified in the SB to ensure
that the unsafe condition is appropriately addressed. The failure to make the distinction
can cause confusion among DAHs, operators, and regulatory authorities when
determining whether approval of an AMOC is necessary to deviate from the SB
incorporated by reference in the AD.
Implementation
The SIWG proposed new guidance material for a DAH AC to provide information to help
creators of service information as well as users of the service information understand the
safety intent of the design change, the configuration that corrects the unsafe condition,
and which tasks are necessary to comply with the applicable AD. The SIWG developed
objective criteria to help determine which tasks should be labeled as RC. General
guidance material and a series of questions was developed to assist in defining and
evaluating the type design change as well as assist in defining objective criteria that could
be consistently used when making the determination whether to label a task as RC. The
general guidance material and the series of questions created should help to define the
specific design change that was created to correct the unsafe condition and will assist in
determining whether a task is a direct part of detecting, preventing, correcting, or
eliminating the unsafe condition that prompted the SB and the consideration of an AD.
The SIWG proposed acceptance of ―refer to‖ and ―in accordance with‖ to differentiate
when the prescriptive procedure must be followed precisely versus when an air carrier
could use their own accepted equivalent procedure. The SIWG also discusses the use of
―refer to‖ and ―in accordance with‖ under section A2.10 Standard Practices.
After the new AC is published, AFS–300 will review FAA Order 8900.1 to determine if
corresponding language should be added to the order for ASIs. The FAA also will update
the AD template to include the new notes that define use of the terms ―refer to‖, ―in
accordance with‖, and ―required for compliance (RC)‖. In addition, the SIWG submitted
a request to update ATA iSpec 2200 and S1000D to include guidance material on RC,
―refer to‖, and ―in accordance with‖.

The SIWG expects that each DAH and regulatory authority will create internal guidance
material based on the information in the industry documents to ensure the standards for
identifying the safety intent, describing the configuration that corrects the unsafe
condition, and identifying the applicable tasks as RC are met during the authoring,
review, and approval of SBs. Training of DAH SB authors, AD writers, DAH and FAA
engineers and FAA inspectors must be developed before implementation of changes to
SBs and ADs. After guidance has been published and training has been conducted,
DAHs can implement the proposed SB changes and the FAA can implement
corresponding AD changes.
Outcome
The SIWG’s proposed implementation actions successfully address the AD CRT
recommendation to revise the way SBs are written to specify the safety intent of an
SB incorporated by reference in an AD and avoid mandating things that are not required
to meet the safety intent of the AD. The new RC concept separates AD requirements
from other material and should facilitate AD compliance determinations.
The FAA revised the AD template to include new notes that define use of ―refer to‖ and
―in accordance with‖.
The SIWG noted that implementation of the RC concept will differ among the various
DAHs. Airbus and Bombardier agreed to identify certain paragraphs such as procedure
and test paragraphs of their SBs as RC, but will not identify specific steps as RC. These
DAHs consider their approach to be an equivalent means to comply with the intent of the
recommendation. See section 2.5.2 for more information.
Note: The FAA plans to issue a revised draft AC 20–xxx, which contains information on
the use of the RC concept and the objective criteria for identifying RC items. After
incorporating public comments, the FAA plans to issue the final AC by the end of 2011.
In addition, the FAA plans to add notes on RC to the AD template upon final issuance of
the AC.
A2.3 Detailed Instructions (Clarify Figures)

Task
Detailed instructions. Service instructions must make clear whether a
figure or drawing is the authoritative instruction or only an installation
aid. Service instruction text and drawings must be in agreement with
each other to avoid subjective misinterpretation. In addition, service
instructions should no longer contain ambiguous terms, such as
―approximately‖, to define allowable tolerance ranges and
performance criteria.

Service instructions often contain detailed figures/illustrations to clarify the task.
However, the detail provided in the figures/illustrations may make it difficult to
determine what parts of the figure/illustration are required for compliance versus
reference only information when an AD mandates accomplishment of the
A solution is needed to ensure the intent of figures/illustrations in service instructions is

clear to include distinguishing between compliance requirements and information
provided for reference only.
Implementation
After considering 12 options that included the use of RC coding, color coding, and text
on the illustration, the SIWG recommended 3 options for implementation that provide
guidance and set a standard on what methods can be used in illustrations to ensure clarity.
The options are—
 Shade/cross hatch on important areas;
 Use phantom lines42 for items in illustrations that are for reference only; or
 Use enlarged view illustrations (currently a standard practice).
In addition, the SIWG developed the following definitions for clarification purposes:
 Illustration—A pictorial graphic.
 Figure—A part of a service document that includes an illustration, photograph,
chart, graph, table, form, note, symbol, callout, text, or dimension (or any
combination) that supports or clarifies the written instructions.
 Drawing—A document created by an OEM/DAH Engineering department to
define configuration. Drawings may include other engineering information such
as specifications, dimensions, materials, and processes.
The SIWG recommended that the FAA create an AC to document the recommended
solutions and include guidance on detailed instructions to provide basic instructions to be
used when creating illustrations. The AC also should specify the need for dimensions
and tolerances in the illustrations to remove ambiguity. The FAA documented the
SIWG’s guidance in draft AC 20–xxx, issued on June 13, 2011.
The SIWG also recommended each OEM/DAH implement methods to prevent use of
ambiguous terms in service documents. The methods include—
 Training—Provide training to authors of service documents to stress the effect of
using ambiguous terms and the importance for providing clarity and accuracy.
42
Phantom lines are lines drawn by alternating a long dash, followed by two short dashes.

 Tools—Such as computing tools or checklists to prevent or search for and
eliminate the inclusion of ambiguous terms.
 Processes—Implement processes used during the authoring, review, validation,
and approval of service documents that will prevent the use of ambiguous terms.
The SIWG provided additional flexibility on the use of figures/illustrations/drawings

under A2.2 Critical Task Differentiation.
The SIWG also submitted change requests to have the suggested guidance material
included in ATA iSpec 2200 and S1000D documentation. The SIWG recognized that
ATA iSpec 2200 and S1000D allow for some flexibility on how each DAH implements
the standards described and therefore, different formats of service instructions result.
The SIWG noted training will be accomplished by the affected organizations as needed.
In addition, each DAH plans to incorporate the concepts and general guidelines
developed into its internal documentation as policy for creating service instructions.
Outcome
The SIWG’s implementation guidance successfully address the AD CRT recommendation
to address ambiguity in terms, distinguish between compliance requirements and
information provided for reference only, and ensure figures in service instructions and
text agree. The draft and final versions of AC 20–xxx and the updated ATA iSpec 2200
and S1000D (anticipated to be issued in 2012) reflect these process changes.
A2.4 Expedite Service Information Development

Task
OEMs should streamline service instruction development and revision
processes to expedite release to air carriers.
According to DAH representatives from Airbus, Boeing, Bombardier, Embraer, and
Learjet on the SIWG, there is no singular or set of process improvements that could be
implemented with each DAH’s internal process and in parallel through their primary
regulatory authority’s approval process. The SIWG noted because each DAH has the
responsibility to address design changes, it becomes more imperative to ensure proper
coordination when safety issues are identified.
In addition, each DAH has systems in place to continuously review and implement
process improvements. These systems are used to improve processes to enhance the
quality of the deliverables to the regulatory agencies and customers as well as reducing
flow time to produce those deliverables. Each DAH must continue to use those systems
to investigate and implement future improvements to improve the quality of the
deliverables while reducing the flow time.

Implementation
The SIWG identified the following existing process improvement projects that have
enhanced (or have the potential to enhance) service instruction development specifically
to reduce flow time and improve quality.
 Quality Improvement Process, such as—
o Safety Management System—A system or process to make sure the action
described in service instructions, including proposed compliance periods, are
soundly based on risk management principles;
o Lean Management System—A system which incorporates tools, principles,
training, and a common language to improve productivity;
o Statistical Process Control—Application of statistical methods to monitor and
control a process to ensure that it operates at its full potential to produce a
conforming product; and
o Six Sigma Improvement Processes—A data driven process used to improve
processes and products.
 Use of checklists—Implemented to assist authors in making sure requirements are
met before documents are sent for approval.
 Use of tip sheets—Implemented to assist authors in understanding requirements.
 Use of boilerplate text—Implemented to standardize the location and content of
text in service documents and to reduce variation.
 Documented standards—Implemented to document standard practices, formats to
reduce variation.
 Documented guidance—Implemented and used by individuals within an
organization to document, understand, and manage information used to create and
publish service information.
 Dispute Resolution Process—A formal process used to resolve differences
between a regulatory agency and the DAH during development of
 Compliance Recommendation Process—A formal process used by a DAH to
develop and communicate recommended compliance action to a
regulatory agency.
 Validation Processes—A formal process used to validate that procedures in
service information are accurate, complete, and can be accomplished.
 Air Carrier Review Process—A formal process in which a copy of service
information is sent to an air carrier prior to publication. The air carrier then
reviews the information and submits comments back to the DAH for
consideration.
 Partial Revision Process—A process in which only changed information in a
service document is sent to affected customers.

 Temporary Revision Process—A process in which only changed information in a
service document is sent to affected customers. The information is later included
in the next revision to the document.
 Contingent Approval Process—A process in which an organization approves a
document contingent upon changes being made prior to publication.
 Prioritization Process—A process in which service documents are prioritized and
work is accomplished based on those priorities and the national authority is
kept apprised.
 Delegated Approval Process—A process in which a regulatory agency will
delegate certain functions be accomplished by the DAH.
 Electronic Signature Process—A process which allows a DAH to use electronic
signatures for certain types of documents
 Information Exchange Process—A process in which a DAH shares information
used to develop service information, for example, posting proposed solutions,
proposed compliance times, estimated part availability dates, and other
information regarding plans for correcting an unsafe condition. Air carriers can
then view the information and provide feedback back to the DAH.
 Airworthiness Concern Coordination Process (ATA Specification 111)—A process
in which a DAH, air carrier operators, and a regulatory agency work together to
develop and accomplish service instructions necessary to correct an unsafe
condition.
Each DAH reviewed the above list and evaluated the possibility of implementing items
from the list, or identified alternatives/equivalents that would improve the availability of
service instructions and the development and delivery of ICA that result from design
changes. Each DAH sent a letter to the AD ARC stating it evaluated the list and provided
what items it will implement or if not, an explanation as to why not.
Outcome
The SIWG’s implementation actions successfully address the AD CRT recommendation
for OEMs to streamline service instruction development and revision processes to
expedite release to air carriers by DAHs evaluating the list of process improvements and
documenting the feasibility of implementing the improvements within its organization.
The AD ARC noted the participating DAHs submitted letters to the FAA43 outlining their
review of the process improvements and implementation plans relative to streamlining
service instruction development and expediting service instruction release to air carriers.
In addition, the FAA issued draft AC 20–xxx, Section 3–11, Streamlining Development
and Revisions of SBs, which includes the majority of the process improvement projects
listed above that reduce flow time and improve quality. The FAA plans to issue the final
AC by the end of 2011.
43
The participating DAH provided letters to the FAA on the following dates: Airbus, June 29, 2011;
Boeing, April 22, 2011, Bombardier, August 19, 2011; and Embraer, July 7, 2011.

A2.5 Flexibility
Task
Flexibility as appropriate. When compatible with the corrective action
intent of the AD, service instructions should incorporate general notes
providing air carriers latitude to use (1) acceptable alternative materials
and approved internal procedures without requesting an AMOC on each
deviation or (2) where applicable, the option to use their
engineering authority.
Service instructions contain detailed step-by-step instructions necessary to perform the
inspection, repair, modification, and/or testing to perform tasks described in the
service instructions. However, these detailed steps often lead to an air carrier/operator
not being allowed to use accepted or approved alternate parts, material, tools, or
processes. This results in an air carrier/operator having to submit a request for an AMOC
each time it wishes to use alternate parts, material, tools, or processes. Some DAHs
currently include general notes in service instructions that give an air carrier/operator
some flexibility to use alternate parts, materials, tools, and processes, but still meet the
design requirements for the aircraft. However, not all DAHs include these types of notes
in their service instructions. In addition, air carriers/operators have identified several
cases that are not addressed by current notes. The SIWG reviewed the notes that
currently exist in various DAH service instructions.
Implementation
The SIWG documented existing and new agreed-upon general notes. Each DAH will
evaluate the notes and incorporate the applicable notes or appropriate similar notes into
their service instructions. Each DAH will need to work with their respective regulatory
authority to obtain concurrence for including the notes that allow air carriers/operators
flexibility.
The SIWG expects each DAH will develop and include guidance for use of general notes
in their internal service instruction preparation documents. In addition, a high-level
recommendation is included in ATA iSpec 2200 recommending general notes that provide
flexibility be included in service instructions. The SIWG is communicating with the
Civil Aviation Working Group responsible for updating S1000D and will submit a change
request to update S1000D by September 30, 2011, to recommend general notes that
provide flexibility be included in that specification document. The SIWG also developed
training material on the use of general notes.
Outcome
The SIWG’s implementation actions successfully address the AD CRT recommendation
by providing a list of general notes to DAHs for inclusion in service instructions. The
general notes enable air carriers/operators to use acceptable alternative materials and

approved internal procedures without requesting an AMOC and provide
air carriers/operators the option to use their engineering authority. In addition, DAHs
agreed to include applicable notes in their service instructions. On June 13, 2011, the
FAA issued draft AC 20–xxx, Section 3–7, General Notes, which provides information
related to the accomplishment instruction steps. The FAA plans to issue a final AC by the
end of 2011.
A2.6 Lead Airline Process

Task
(1) Revise ATA Specification 111 for improvements to the Lead Airlines Process.
(AD CRT task 1 report, recommendation No. 2—

Service Bulletin Process)
(2) The ATA should review and update ATA Specification 111 to address issues
brought forward in this report with emphasis on the following items:
 A goal of the Lead Airline Process should be to contribute to clear and
accurate service instructions that avoid prescriptive processes where
standard practices are available and applicable. Ideally, these instructions
contribute to effective implementation by a technician. The process
should lend particular attention to developing service instructions
involving previous overlapping ADs or a series of ADs or SBs on (1) the
same component, (2) wiring and other actions dependent on workmanship,
and (3) class 220 type actions that are easily reversible in future
maintenance. In these cases, prototyping of proposed service instructions
on in-service airplanes is particularly important, and OEM participation
should be considered. The process should—
o Identify differences in airplane configurations relevant to the proposed
o Ensure lead airlines are selected according to qualifications, capability,
and commitment to the process.
o Predispose service instructions to support AD compliance planning
objectives cited in the following two bullet points.
 The ATA should periodically review the Lead Airline Process to ensure the
continuing effectiveness of the process.
 The ATA should coordinate the update to ATA Specification 111 with the
OEM. This will help to streamline and better integrate the Lead Airline
Process with OEM fleet support processes.
(AD CRT task 2 report, recommendation No. 3, bullet Nos. 1, 2, and 3)

Under part 39, the FAA issues ADs to mandate action by airplane owners/operators to
correct ―unsafe conditions‖. Experience has shown that the most effective and efficient
means of identifying and responding to potential safety-related problems, and
determining and resolving unsafe conditions, requires aggressive fact finding and
coordination among equipment manufacturers, airplane operators, and the government
airworthiness authority. Note that foreign equipment manufacturers and/or DAHs will
use their respective processes as appropriate.
The ATA published Specification 111 to provide a method to coordinate the resolution
of unsafe conditions. The ACCP is a cooperative process that allows the commercial
aviation industry to capitalize on the expertise of equipment manufacturers, air carrier
operators and the FAA to address an unsafe condition with optimum effectiveness,
timeliness, and efficiency. The purpose of the process is to produce the most effective
resolution by enhancing communications between the principle parties that could
be affected.
Currently, ATA Specification 111 states that an ACCP starts with the identification of a
―potential airworthiness concern‖ and the gathering of related data and information.
Subsequently, when the concern is determined to be a ―safety-related problem‖ that the
FAA decides to resolve by AD, the FAA is subject to ex parté constraints and the ―Lead
Airline Process‖, a subcomponent of the ACCP, begins with the OEMs and air carriers
collaborating to develop corrective service instructions. At any time during an ACCP,
concluding with the release of an AD NPRM or urgent AD, the FAA may request data
or information, including requests from those participating in Lead Airline
Process subcomponent.
Although ATA Specification 111 processes can and have been performed in coordination
with other DAHs (production approval holders and supplemental type certificate
holders), those efforts are best addressed with ad-hoc arrangements. The majority of
AD initiatives involve only airplane or engine DAHs.
A primary objective of the process is to develop, to the greatest extent possible, OEM
service instructions and/or other approved service instructions that will be incorporated
by reference to accomplish the technical, maintenance, logistic, and other requirements of
ADs, and the needs of operators in implementing those requirements. The involvement
of principle parties early in the development of service instructions is crucial in meeting
this objective.
Ideally, the process facilitates FAA development of an AD through straightforward

IBR of service instructions. The SIWG acknowledged ATA Specification 111 has
not been updated since 2000 and does not reflect today’s DAH and air carrier
internal processes.

Implementation
The SIWG’s implementation action included—
 Reviewing and updating ATA Specification 111 to address issues identified in the
AD CRT task 1 and task 2 reports;
 Developing metrics and a process to periodically review the Lead Airline Process
to ensure continued effectiveness of the process; and
 Coordinating the update of ATA Specification 111 with OEMs and all
affected parties.
The SIWG noted each OEM, air carrier, and regulatory authority will determine which
portions of the specification it chooses to implement and how to accomplish the tasks
recommended in the specification. In addition, the ATA will make the specification
available to aviation organizations normally not involved with Lead Airline Process so
that they may arrange similar process specifications, as necessary.
The SIWG also noted air carriers, DAHs, and regulatory authorities should provide
training to organizations and individuals that implement the process.
Outcome
The SIWG successfully addressed the AD CRT recommendation by providing its draft
revision of ATA Specification 111 to ATA. ATA and the ATA Airworthiness Committee
plans to publish the revised specification by October 31, 2011. If effectively coordinated,
the revised process will yield benefits not originally realized with ATA Specification 111.
The following are considered specific objectives and measurements of the success of
the process:
 Foster mutual understanding and awareness of safety issues, risks, and margins.
 Foster appropriate compliance through clear and concise technical data.
 Minimize differences between the coordinated and the final service instructions
required to address the unsafe condition.
 Minimize differences between the manufacturer’s service instructions and
instructions in the AD.
 Minimize occurrences of corrections to ADs, including corrective revisions and
supersedures of ADs.
 Minimize the need for AMOCs, and AD extensions and exemptions.
 ATA plans to sponsor training, particularly for lead airline designees, focused on
the substantial revision of the ATA Specification 111 and related
AD ARC products, and the FAA part 39 legal interpretation.
 In addition, ATA plans to coordinate training, particularly for operator employees
involved in engineering and maintenance regulatory compliance, for AC 39–9, the
final version of AC 20–xxx, and the FAA part 39 legal interpretation.

A2.7 Maintaining Airworthiness
Task
OEMs and the ATA, as appropriate, should avoid drafting class 2 SBs.
Maintaining airworthiness. Service instructions should be written and

traceable to avoid situations where previous AD compliance requirements
are inadvertently undone or modified through routine air carrier
maintenance. (Refer to class 2 issues in section 2.2.5 and finding and
recommendation No. 11, for additional information regarding this issue.)
Air carriers use service instructions such as SBs to initially comply with an AD.
Subsequent maintenance is performed using a combination of the methods, techniques
and practices prescribed in the DAH’s instructions for continued airworthiness and an
operator’s own maintenance practices developed under § 43.13(c). If these procedures
fail to take the AD-mandated requirements into consideration, the operator could become
out-of-compliance with the AD. To decrease that chance, the DAH’s and operator’s
procedures need to be updated to support AD-mandated changes to ensure the
AD configuration and other requirements are taken into account during normal
maintenance. DAH’s procedures and ICA44 should also clearly show the relationship to
any AD or to the AD-mandated service instruction such as an SB.
Implementation
To avoid situations where previous AD compliance requirements are inadvertently
undone or modified through routine air carrier maintenance, the SIWG proposed the
following improvements:
(1) Increased review of service information documents by air carriers and DAHs
during SB development to evaluate the need for changes to ICA to eliminate the
potential for undoing a mandated condition or configuration,
(2) DAHs providing awareness to the air carrier regarding availability of updated
ICA documents,
(3) DAHs utilizing the flexibility provided in general notes and referring to standard
practices as much as possible in SB instructions that will be incorporated by
reference in ADs,
44
ICA consists of documentation that provides methods, techniques and practices for accomplishing
maintenance and preventative maintenance including inspections that are essential to the continued
airworthiness of an aircraft.

(4) DAHs avoiding duplication of entire procedures from non-approved manuals in
SBs by listing only the specific requirement that must be met in the SB and
placing internal flags in those manuals to trace the requirement if compliance is
required by an AD or is expected to be required by an AD in the future,
(5) DAHs creation of an SB-to-AD cross-reference listing upon release of the
AD, and
(6) DAHs and operators support proposals to prevent the inadvertent undoing of
ADs submitted by other working groups.
The solutions presented above will be included in AC 20–xxx. Each DAH will be
responsible for developing processes and training the affected personnel on how it plans
to adopt any of the recommended best practices.
Outcome
The SIWG successfully addressed the AD CRT recommendations to avoid situations
where previous AD compliance requirements are inadvertently undone or modified
through routine air carrier maintenance by the FAA’s issuance of draft and final versions
of AC 20–xxx. The AC provides guidance to DAHs in chapter 6 on maintaining
airworthiness that includes the SIWG suggested improvements on general notes, ICA,
use of internal flags in non-approved manuals, and the creation of an SB-to-AD
cross-reference listing to help owners/operators avoid inadvertently undoing or
modifying AD-mandated type designs through routine maintenance.
A2.8 Maintain Airworthiness—Production versus In-service Maintenance

Task
The AD ARC assigned a new task to the ADWG concerning maintenance
of design changes that are required by an AD. The ARC asked the
ADWG to consider including a section in ADs, and possibly the
AD Manual, AD worksheet, and/or AD template, to address maintenance
of mandatory design changes. The ARC asked the SIWG to work with
the ADWG to create a method in which a mandated design configuration
is maintained.
The issue concerning maintenance of mandatory design changes was identified during
FPWG discussions concerning recommendation No. 12, involving proposed revisions to
§§ 39.7 and 39.9. The FPWG identified two main issues in its summary sheet (see
section D2.5 of this report) on this subject:
(1) The difference in regulatory treatment between an aircraft that has had design
changes incorporated during production and an aircraft that has been modified in
accordance with an AD to incorporate the same design change. In the first
instance, the maintenance program can handle any deviations from the
configuration under § 43.13, while in the latter instance, deviations must be
handled through the AMOC process.

(2) There were discussions of whether the product or article could return to the
operator’s maintenance program (i.e., be maintained or altered under part 43) after
a terminating action was accomplished.
The ADWG proposed new AD text to address maintenance of design changes mandated
by ADs. For these types of design changes, the new AD text was intended to:
 Require operators to incorporate any new AWLs that are needed to prevent
reintroducing the unsafe condition. (Note that the SIWG considered the process
for identifying new AWLs).
 Allow the design change to be maintained using normal maintenance activities
(that is, acceptable methods, techniques, and practices) provided all applicable
AWLs are complied with.
The proposal depends on the development of new AWLs to protect safety-critical

configurations that are mandated by AD. The new AWLs would supplement Appendix H
to part 25—Instructions for Continued Airworthiness, limitations to prevent previous
AD compliance requirements from becoming undone or modified during normal
maintenance activities or during airplane operation. The new AWLs would apply to
airplanes that incorporated the design change in production as well as airplanes that
incorporated the design change in service through AD compliance, thereby addressing the
FPWG issue No. 1 described above. FPWG issue No. 2 described above is addressed in
a discussion under Maintenance in ADs in section B2.2, Effective and Efficient
AD Process.
The SIWG understood that because the regulation that requires a DAH to provide AWLs
for structural inspection procedures approved under § 25.571, critical design
configuration control limitations, approved under § 25.981 for the fuel tank system, and
mandatory replacement of EWIS components as defined in § 25.1701; the creation of
new AWLs outside the scope of § 25.571, § 25.981, and § 25.1701 would be voluntary.
The DAH participating on the SIWG discussed their practices to evaluate all changes to
type design, including those related to ADs, for follow-on maintenance requirements.
Those requirements, when applicable, are included in the existing or supplemental ICAs.
Therefore, some SIWG members believed that those ICAs should be sufficient for
maintaining the design configuration.
To support the solution proposed by the ADWG the SIWG was tasked to develop a
process for determining appropriate AWLs to prevent previous AD compliance
requirements from becoming undone or modified during normal maintenance activities or
during airplane operation for design changes required by ADs. The process should
identify AWLs that are needed to protect safety-critical features in these designs from
changes to these designs through maintenance activities or normal operation of the
aircraft. The AWL process should involve DAHs proposals for new AWLs during
certification when AD-related design changes are proposed to the FAA, followed by FAA
review and approval of the new AWLs as part of the amended type design.

The SIWG could not agree on the creation and use of AWLs outside of the requirements
of appendix H to part 25 to protect safety critical configurations from changes to designs
through maintenance activities or airplane operation. The concept of creating AWLs
would require that a DAH identify the detailed critical elements of the design change in
an SB, and identify the steps necessary to label those critical elements as RC. However,
DAHs have stated they will not identify the critical elements at the detailed level.
Therefore, it was felt by some SIWG members that it would be difficult to create AWLs if
the detailed critical elements are not identified in the SB.
The SIWG also reviewed 10 recently published ADs to determine if an AWL-type task
would be required to prevent previous AD compliance requirements from becoming
undone or modified during normal maintenance activities or during airplane operation.
The SIWG found that 8 of the 10 ADs reviewed would require some sort of AWL to
prevent the previous AD compliance requirements from becoming undone or modified
during normal maintenance activities or airplane operation. The SIWG also considered
11 alternatives and presented pros and cons for each alternative before it concluded
its review.
Implementation
Because the SIWG could not reach consensus on the proposed solution, no
implementation is planned concerning development of new AWLs intended to prevent
previous AD compliance requirements from becoming undone during normal
maintenance activities or airplane operation.
Outcome
The SIWG was unable to resolve the AD ARC’s task to create a method in which a
mandated design configuration is maintained. The AD ARC later determined that the
task was outside the scope of the AD CRT and IRT recommendations.
A2.9 Simplified Service Bulletin Format

Task
The Team acknowledges the benefits of current AD-friendly
SB improvements, but recommends more focus on user-friendly
improvements in service instructions as follows:
Simplified format. Service instructions can be written in a simplified

format that allows easy translation into an air carrier’s work instructions.
Standardizing service instruction format will facilitate user effectiveness
by repetition in knowing where critical information is referenced.

The aviation industry currently has specifications to define the format, content, and
location for material in various service documents. These industry specifications are
contained in ATA iSpec 2200 and S1000D. These two documents are used by the DAHs
supporting the AD ARC and are used to standardize the location, content, and format of
the material in their service documents. Following the standards defined in those
specifications will help to facilitate user effectiveness by repetition in knowing where
critical information is referenced and the type of content to be included.
Each DAH has its own processes for creating, approving, and distributing service
documents. Each participating DAH committed to consider the implementation of
standard format and layout as given in iSpec 2200 and S1000D. In addition to this, all of
the SIWG’s recommendations as part of the AD ARC activity will positively influence
the overall quality and clarity of service instructions distributed to operators.
The SIWG’s recommendations below are specific to SBs listed as the means of
compliance for an AD.
A summary of recommendations and the proposed solutions are listed below; details
on the solution for each is provided in the section discussion for that specific
recommendation.
 Only the safety-related issue must be addressed. Service bulletins will not include
extra tasks that are convenient to do while in the work area. Critical task
differentiation concept will be applied. The FAA will ensure that items in the SB
that are required for compliance to an AD are clearly identified. This will allow
other actions to be accomplished using an air carrier's procedures or common
industry practices. See section A2.2.
 ICAs should be published before or at the same time as the SB. This will ensure
an operator fully understands and administers the post SB incorporation of ICAs
before completion. See section A2.7.
 Lead Airline Process will be reviewed/updated as needed. The updated
process will provide a method for a ―Lead Airline‖ to review and comment on
SB instructions before the DAH publishes them. This will improve the ability for
air carriers to accomplish the modification and reduce the need for submitting
requests for AMOCs. See section A2.6.
 When acceptable, general notes will be added to the SB to allow air carriers to use
(1) acceptable alternative materials and approved internal procedures without
requesting an AMOC on each deviation or (2) where applicable, the option to use
their engineering authority. This will provide air carriers flexibility to accomplish
tasks in an SB that are not required by the AD, that incorporates the SB by
reference, or use common industry practices without the need for an AMOC yet,
remain in compliance with the applicable AD. See section A2.5.

 When needed, logic-based decision diagrams will be added in service instructions
to assist air carriers in choosing the best corrective action path, such as continued
repeat inspection or termination action, based upon the discovered condition and
compliance time period. Logic Diagrams will be added as an aid to better
understand complex modifications and choose the solution that works best for
each air carrier. See section A2.1.
 It is agreed that the illustrations will be secondary to the text and that differences
between an illustration and the associated text must be avoided. The use of
ambiguous terms such as ―approximately‖ must not be permitted where defining
allowable tolerances and performance criteria. See section A2.3.
 DAHs will adopt a continuous improvement philosophy concerning streamlining
service instruction development and revision process to expedite release to
air carriers. See section A2.4.
Implementation
Implementation of the solutions (such as separating critical tasks from non-critical
flexible advisory tasks, referring to industry standard practices when possible, including
general notes in SBs to provide flexibility, including logic based diagrams in complex
SBs, and clarifying whether information in figures is authoritative or reference only) are
addressed by the implementation of the tasks in this section. Each DAH will also
evaluate each of the applicable recommendations proposed by the SIWG and work with
its regulatory authority to incorporate the recommendations into their products
and processes.
Outcome
The SIWG successfully addressed the AD CRT recommendation by identifying industry
specifications ATA iSpec 2200 and S1000D as the standard reference for service
information format and content and directing each DAH to evaluate the SIWG
implementation actions for each task in this section and incorporate them into their
products and processes as applicable.
In addition, on June 13, 2011, the FAA issued draft AC 20–xxx, which provides guidance
on format and content for service instructions as discussed in this section. The FAA plans
to issue a final AC by the end of 2011.
A2.10 Standard Practices

Task
Standard Practices. The aviation industry has many processes for
performing maintenance and modifications that have been standardized
and proven effective. Service instructions should refer to these standard
practices in which air carriers have experience, confidence, and training.

Operators often have their own acceptable procedures that can be used to accomplish
some of the SB actions. Some confusion and unnecessary AMOCs may be avoided by
ensuring that AD-mandated SBs specify which procedures must be followed exactly and
which can be accomplished using an air carrier’s equivalent procedures.
Implementation
The SIWG noted that in 2006, one DAH signed an agreement with the Seattle Aircraft
Certification Office (SACO) and the Los Angeles Aircraft Certification Office (LAACO)
to implement ―AD-friendly SBs‖. This agreement contained numerous principles and
practices that were developed by a DAH/FAA team. Some of the agreements
implemented were:
 The phrase ―in accordance with‖ will be used to identify procedures that must
be followed.
 The phrase ―refer to…as an accepted procedure‖ will be used to identify
procedures that can be used, but for which an air carrier or maintenance provider
may use their own accepted methods, techniques, and practices.
 A general note describing use of ―in accordance with‖ and ―refer to‖ will be
included at the beginning of the SB accomplishment instructions.
Implementation of this AD-friendly SB improvement initiative has helped by allowing

operators to use their own accepted procedures, without having to request an AMOC, in
cases where DAH’s procedures are not required to address the unsafe condition. There
has been some concern that there is not adequate guidance for the DAHs and the FAA to
determine whether procedures should be identified by the phrase ―in accordance with‖ or
by the phrase ―refer to…as an accepted procedure‖. There has also been concern that in
some cases, ASIs tasked with ensuring that air carriers are in compliance with ADs may
not be aware of the allowable differences in the accomplishment of ADs for procedures
identified with these two phrases. The SIWG determined that a general note describing
use of ―in accordance with‖ and ―refer to‖ will be included at the beginning of the SB
accomplishment instructions.
General Note
One DAH currently includes a general note that gives air carriers some flexibility to use
alternate processes or procedures, but still meet the design requirements for the aircraft.
One DAH also currently includes guidelines in their SB development process to
determine when to use the note. However, not all DAHs include this type of note in their
SBs or have guidelines when it is appropriate to use the note.

The SIWG reviewed one of the general notes that currently exists in at least one DAH’s
SBs related to the use of an air carrier accepted equivalent processes or procedures. The
SIWG believed there was merit in making the note, or a similar version of the note,
available for use by all DAHs. Each DAH will review the note and incorporate it into its
SBs and will review the guidelines for appropriate use of the note and incorporate those
guidelines into their SB development process and documentation. The suggested note is
as follows:
These work instructions refer to methods, techniques, and practices

described in other (Design Approval Holder name) documents. When the
words ―refer to‖ are used and the air carrier has other acceptable methods,
techniques, and practices (including tools, equipment, and test
equipment) those acceptable methods, techniques, practices (including
tools, equipment, and test equipment) can be used to complete the work.
When the words ―in accordance with‖ are included in the instruction, the
methods, techniques, and practices specified (including tools, equipment,
and test equipment) in the (Design Approval Holder name) document
must be used.
“Refer To” and “In Accordance With”

The SIWG proposed using the following guidelines for determining when to use
―refer to‖ or ―in accordance with.‖
 Provide maximum flexibility for the operator when determining if a referenced
process or procedure may be followed or must be followed and
 Processes or procedures that may be followed provide more flexibility to the
operator than processes or procedures that must be followed. Use ―in accordance
with‖ when referring to a process or procedure which must be followed exactly to
correct the unsafe condition and comply with the anticipated AD, otherwise use
―refer to.‖
Refer To
Use ―refer to‖ when referring to standard practices in which an air carrier may use
methods, techniques, and practices accepted by their regulatory authority. Examples of
accepted methods, techniques, and practices include:
 Airplane Maintenance Manual (AMM) procedures for access,
removal/installation, and test;
 Standard Overhaul Practices Manual procedures;
 Standard Wiring Practices Manual (SWPM) procedures;
 Overhaul Manual and Component Maintenance Manual (CMM) for disassembly,
assembly and test procedures;
 Structural Repair Manual chapter 51 procedures that provide common industry
practices (such as drilling holes or installing fasteners);

 Fault Isolation Manual procedures; and
 Generic or common NDT manual procedures not developed for a specific service
instruction application.
In Accordance With
In a situation in which standard practice must be followed exactly to correct the unsafe
condition and comply with the anticipated AD, then accomplish the following:
 Use ―in accordance with‖ when referring to the process or procedure.
 Consider repeating the steps of the process or procedure in the SB.
 Consider internally identifying the process or procedure in the standard practice
documentation’s management system as related to a safety issue for a specific
airplane configuration with a note not to change the process or procedure without
full consideration of the consequences.
As part of this proposal, each DAH will review the note and incorporate it, or an
appropriate similar note, into the SBs as appropriate. In addition, each DAH will review
its SB development process and documentation and incorporate the guidelines for the use
of the note as appropriate or develop similar guidelines for the use of the note.
Each DAH will evaluate the suggested note and the guidelines and incorporate the
note and the guidelines or an appropriate similar note and or guidelines into its SBs
and its SB development process. The SIWG expected that each DAH would develop
and include guidance for use of the note and guidelines in their internal
SB preparation documentation.
In addition, ATA will include a high-level recommendation in ATA iSpec 2200 that the
general note that provides flexibility in the use of processes and/or procedures be
included in SBs. A change request will be submitted to the Civil Aviation Working Group
responsible for maintaining S1000D to recommend a general note providing flexibility in
the use of processes and/or procedures be included in that specification document.
Guidance material, including the note and guidelines, will be included in the draft and
final versions of AC 20–xxx.
Use of the concept to use ―refer to‖ and ―in accordance with‖ terminology has been
discussed with the European Aviation Safety Agency (EASA) and the National Civil
Aviation Agency of Brazil (ANAC). These regulatory authorities have agreed with the
concept for using the specified terminology and will work with their respective DAHs to
implement the solution. The solution has been discussed with Transport Canada but they
have not provided a response. The SIWG did not anticipate that Transport Canada will
have concerns with the concept and believed Transport Canada would support
the solution.

Outcome
The SIWG successfully addressed the AD CRT recommendation to reference industry
standard practices in which operators have experience, confidence, and training by
formalizing the use of ―refer to‖ and ―in accordance with‖ (currently an AD-friendly
principle) in advisory material and FAA guidance.
In addition, on June 13, 2011, the FAA issued draft AC 20–xxx, which provides guidance
on the use of ―refer to‖, ―in accordance with‖ as discussed in this section. The FAA plans
to issue a final AC by the end of 2011.
A3.0 CONCLUSION
The SIWG addressed each recommendation assigned by the AD ARC. The
implementation actions discussed above improve the process for developing service
instructions and prevent requiring actions that do not meet the safety intent of an AD.
The improvements in the development of service instructions are as follows:
 Created and documented standards for logic-based diagram format, content, and
location to assist operators in choosing the best corrective action for complex
service instructions. The FAA documented the standards for logic-based diagrams
in draft AC 20–xxx. ATA included high-level standards for logic-based diagrams
in ATA iSpec 2200. A change request will be submitted to include the high level
standards in S1000D.
 DAHs committed to include logic-based diagrams in complex
 Provided a list of general notes to DAHs for inclusion in service instructions to
enable operators to use acceptable alternative materials and approved internal
procedures without requesting an AMOC and provide operators the option to use
their engineering authority.
 Created guidance to understand the safety intent of the design change, the
configuration that corrects the unsafe condition, and the tasks necessary to comply
with an AD. Developed criteria to help identify tasks that should be labeled RC.
 Finalized the use of ―refer to‖ and ―in accordance with‖ to differentiate when a
prescriptive procedure must be followed exactly versus when an operator can use
its own accepted equivalent procedure.
 Set a standard for the use of shading, phantom lines, and enlarged views to be
used in illustrations to ensure clarity; developed definitions for the terms
―illustration‖; ―figure‖; and ―drawing‖ for clarification purposes; and
recommended DAH’s prevent the use of ambiguous terms in service information
through training, computing tools or checklists; and the implementation of
processes during the drafting, review, and approval of service documents.
 Identified existing process improvements that enhance service instruction
development to reduce flow time and improve quality.

 Revised the Lead Airline Process and developed metrics to periodically review
the Lead Airline Process to ensure its continued effectiveness.
 Developed process improvements for DAH to ensure operators maintain
airworthiness through evaluating the need for ICAs, making operators aware of
updated ICAs, using general notes to provide operator flexibility and standard
practices in SBs when possible, and creating an SB-to-AD cross-reference listing.
 Established guidance on format and content in service instructions.

APPENDIX B—AD DEVELOPMENT WORKING GROUP
B1.0 INTRODUCTION
The AD ARC formed the ADWG to address AD CRT recommendations related to the
development of ADs. The ADWG’s key objective is to ensure the AD development
process is effective and efficient.
The ADWG is comprised of 16 members representing AFS, AIR, foreign aviation

authorities, U.S. air carriers, U.S. and foreign airplane manufacturers, and repair stations.
The ADWG met on three occasions and held monthly teleconferences to evaluate and
develop implementation actions for its assigned recommendations. The ADWG co-leads
tracked the working group’s progress using project plates that contained the assigned
recommendation, the expected outcome/deliverables, and individual milestone tasks. The
ADWG co-leads provided status updates to the AD ARC members at the ARC meetings
noting if the working group would meet its schedule to complete its review and analysis
of the assigned recommendations or had encountered difficulties.
B2.0 ASSIGNED TASKS

The AD ARC assigned the ADWG the following seven recommendations to evaluate and
 Clarify ex parté communications;
 Resolve finding 4 (AD CRT identified systemic problems in the AD process);
 Ensure AD process is effective and efficient (address ICA);
 Post NPRM/FR service information for public access;
 Include the first compliance deadline in the AD NPRM and final rule AD;
 Develop AD tracking and management for multiple SBs and ADs; and
 Extend comment period for MCAI NPRMs to 45 days and harmonize
FAA/foreign national aviation authorities (NAA) AD Processes.
The ADWG documented its evaluation of each recommendation and the implementation
action in a summary sheet report. The ADWG addressed the seven recommendations in
seven summary sheets. The complete unedited working papers that document the
AD ARC’s working groups’ review, analysis, and decisions are available for viewing and
download from the AD ARC Web site at
http://www.faa.gov/aircraft/air_cert/continued_operation/ad/ad_arc/. Each assigned task,
its implementation action, and outcome are excerpted from the ADWG summary sheets
and presented below.
Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page B–1

B2.1 Earlier Service Bulletin Credit
Task
ADs generally have an aggressive installation timeline. Because of the
urgent nature of AD tasks and the need for planning to minimize aircraft
out-of-service time, air carriers frequently accomplish service instructions
ahead of the AD issuance date. This creates an exposure to
noncompliance when there are changes in the final AD that differ from
the originally released service document.
Charter a joint team made up of representatives from the FAA, OEMs,

and air carriers to resolve finding No. 4. The overarching goal is to
ensure that the AD development process is effective and efficient and
results in a compliant product for air carriers.
(AD CRT task 2 report, finding No. 4, bullet No. 3 and recommendation
No. 4, bullet No. 1)
Operators often accomplish actions in an SB when the DAH initially releases the bulletin
or upon FAA issuance of the NPRM. In doing so, operators risk noncompliance with the
final rule AD if the mandated SB revision level is not the same as the one accomplished.
In such cases, an AMOC must be approved to address differences between the various
revision levels of the SB and additional work may be required to comply with the AD.
Implementation
The latest FAA revision to the AD Manual, chapter 8, specifies when appropriate, to
allow credit for actions accomplished using an earlier revision of the service information
than identified in the AD action.
The ASE will identify on the AD worksheet whether credit can be given for actions
accomplished using an earlier revision of the service information. In addition, the
AD template includes a compliance paragraph, regarding credit for actions accomplished
using an earlier revision of the service information.
Outcome
The ADWG found the implementation actions successfully address AD CRT task 2
report, finding No. 4, bullet No. 3 with the FAA’s issuance of revisions to the
AD Manual, and implementation of the standardized AD worksheet and template in
August 2010.

B2.2 Efficient and Effective AD Process
Task
The overarching goal is to ensure that the AD development process is
effective and efficient and results in a compliant product for air carriers.
(AD CRT task 2 report, recommendation No. 4, bullet No 1, part 2)
Minimize the number of AMOCs for ADs that require design changes.
(AD ARC, March 2010)
Consider including a section in ADs, and possibly the AD Manual,

AD worksheet, and/or AD template, to address maintenance of
mandatory design changes.
(AD ARC, September 2010)
The ADWG reviewed, analyzed, and evaluated the assigned tasks as described above and
addressed the following concerns from the AD ARC and operators.
When ADs require installation of a specific design, operators must currently request
AMOCs to install later approved designs, even if the DAH develops and the FAA
approves the designs. To reduce the resources needed to request and approve AMOCS,
the AD ARC asked the ADWG to consider options for minimizing AMOCs for ADs
requiring design changes.
Operators also requested clarification on when a product or article can return to the
operator’s maintenance program, that is, be maintained or altered under part 43 after a
terminating action in an AD is accomplished.
Implementation
Effective and Efficient AD Process
The ADWG concluded that all of the improvements to the AD process as implemented
will contribute to a more effective and efficient AD process. The ADWG found that the
AD ARC’s proposed AD process improvements, in conjunction with the FAA’s QMS,
will help ensure that the AD process is effective and efficient.

In addition, the results of the FAA’s oversight activity are evaluated for continual
improvement. The TAD will continue to review the measures used to evaluate the
timeliness of AD processes, including the timeliness of processing AMOCs, and to
oversee compliance with the process through regularly scheduled audits or assessments.
As the TAD establishes an internal SMS (in support of continuous improvement), it will
provide increased focus on the required safety controls of the process; the relation of the
process to the FAA’s safety goals and objectives; and control of the potential hazards
associated with performing the process.
Later Approved Parts

The ADWG concluded that the end goal of the AD ARC’s recommendation to minimize
the number of AMOCs for ADs that require design changes is to allow use of ―later
approved parts‖ without the need for an AMOC. For example, if an AD requires
replacement of a –1 part with a –2 part, and a –3 part is subsequently approved as an
alternative to the –2 part, then the objective would be to develop a method that would
permit use of the –3 part without the need of an AMOC. The ADWG proposes to allow
―later approved parts‖ in service information that is incorporated by reference in an AD.
The service information language would allow installation of a DAH’s parts that are
approved after the release date of the service information. The ADWG proposes
transferring implementation of the ―later approved parts‖ language in the service
information with the following considerations:
 The decision whether ―later approved parts‖ are acceptable without an AMOC
should be considered on a case-by-case basis.
 Because operators may not have easy access to information concerning the date a
part is approved, the ADWG recommends that the service information for the
―later approved parts‖ include some type of recognition that the part complies
with the applicable AD. This will ensure operators know which parts are
acceptable for installation per the AD.
Maintenance in ADs
The ADWG proposed new AD text to address maintenance and/or preventive
maintenance of design changes or repairs required by ADs that do not impose
post-modification requirements (such as post-modification repetitive inspections). For
these types of ADs, the new AD text is intended to allow certain aspects of the design
change to be maintained using normal maintenance activities (that is acceptable methods,
techniques, and practices). The new text will be included in the AD template and should
be included in certain ADs that require design changes or repairs and that do not impose
post-modification requirements. An example of this text is as follows:

(g) Required Modification or Repair
Maintenance
Note: After accomplishing the actions required by paragraph (g),
maintenance and/or preventive maintenance under part 43 is
permitted provided the maintenance does not result in changing the
AD-mandated configuration (reference § 39.7).
The ADWG also proposed a solution to an issue the AD ARC raised concerning a
difference in regulatory treatment between an aircraft that has had design changes
incorporated during production and an aircraft that has been modified in accordance with
an AD to incorporate the same design change. In the first instance, the maintenance
program can address any deviations from the configuration under § 43.13, while in the
latter instance, deviations must be addressed through the AMOC process. To address this
discrepancy, the ADWG proposed new AD text to permit maintenance under part 43 after
accomplishing a mandatory design change or repair. This proposal depended on the
development of new AWL to protect safety critical configurations mandated by an AD
that would apply to airplanes that incorporated the design change in production as well as
airplanes that incorporated the design change in-service through AD compliance.
The proposed AWLs would supplement part 25 Appendix H, Instructions for Continued
Airworthiness, limitations to address maintenance of design changes required by AD.
Therefore, development of these AWLs would be voluntary for DAHs. The AD ARC
considered the voluntary nature of this proposal to be a significant limitation to
its success.
The AD ARC asked the SIWG to review and consider implementation of the proposal for
new AWLs in coordination with the ADWG. The SIWG reviewed the AWL proposal, and
was not able to reach consensus on implementation plans (see section A2.8 of this report).
Therefore, the ADWG proposal regarding AWL will not be implemented as part of the
AD ARC activity.
Outcome
The ADWG’s implementation actions successfully address AD CRT recommendation and
AD ARC tasks. The collective efforts of the ARC’s implementation actions will assist
with ensuring the AD process is efficient and effective.
In addition, allowing certain later approved parts to be installed without the operator
requesting an AMOC contributes toward the effectiveness and efficiency of the
AD process. On June 13, 2011, the FAA issued draft AC 20–xxx, which includes a
discussion of the use of ―later approved parts‖ language in the SB in section 5–5,
Minimizing AMOCs for Design Changes. The FAA plans to issue a final AC by the end
of 2011.

Finally, allowing certain aspects of the design change to be maintained using normal
maintenance activities (that is acceptable methods, techniques, and practices) instead of
operators requesting an AMOC to maintain any aspect of AD configuration also increases
the efficiency and effectiveness of the AD process.
B2.3 Ex Parté Communications

Task
The ATA, in coordination with the FAA, should take steps to clarify to
the industry and FAA personnel that ex parté communications can take
place if the communications are fully documented and placed in the
rulemaking docket for public review.
The AD CRT requested clarification about ex parté communications during
AD rulemaking,
As stated in appendix 1 to 14 CFR part 11, ―[a]n ex parte contact involving rulemaking is
any communication between FAA and someone outside the Government regarding a
specific rulemaking proceeding, before that preceding closes.‖ Appendix 1 to part 11
specifies the requirements for ex parté contact with the public during any rulemaking
process. In particular, ex parté contacts are improper if they affect the basic openness and
fairness of the rulemaking process. Therefore, if such a communication is made, the FAA
is directed to place a summary of the discussion in the docket to ensure the public is
aware of the contact and its outcome.
Implementation
The May 17, 2010, revision to the AD Manual, chapter 3, clarifies the meaning of an
ex parté contact and when it is improper; identifies where to record ex parté
communication; and provides helpful precautions and practices during the rulemaking
process (that is, prior to issuance of notice, during the comment period, after the
comment period closes, and after a meeting is announced to the general public.)
Although the AD Manual is available to both the FAA and public through the Regulatory
and Guidance Library Web site, http://rgl.faa.gov, the FAA is the primary audience for the
AD Manual. As such, the FAA included a reference to the section in the AD Manual on
ex parté communications in a new AC on DAH best practices with regards to ADs. In
addition, ATA revised ATA Specification 111 to include a discussion of ex parté contacts
in Appendix B.

Outcome
The ADWG’s implementation actions successfully address AD CRT recommendation
with the FAA’s issuance of chapter 3 of the AD Manual, and the draft and final versions
of AC 20–xxx. Chapter 2 of the AC references ex parté communications. In addition,
ATA revised ATA Specification 111 to include a discussion of ex parté communication in
Appendix B based on the above FAA guidance.
B2.4 First Compliance Date

Task
At a minimum, the first compliance deadline should always be stated in
the NPRM and AD.
(AD CRT task 2, recommendation No. 4, bullet No. 4)
Historically, the FAA’s TAD specified compliance times in detail in the regulatory text of
transport AD final rules. However, because SBs may involve complex compliance times
that affect multiple aircraft configurations restating these times in the regulatory text of
an AD often requires revising the compliance time terminology presented in the SB to
ensure the language used in the AD is legally enforceable. In restating compliance times,
the FAA might inadvertently introduce errors. In addition, restating those compliance
times from the SB can result in very lengthy ADs. Therefore, as part of the AD-friendly
SB initiative,45 certain manufacturers have agreed to develop SBs using regulatory
compliance terminology so that ADs can simply state the appropriate compliance section
of the SB rather than restating the compliance times. Because the public may not have
access to certain SBs, it would not have access to detailed compliance times for the
associated ADs. Therefore, the AD CRT proposed ―at a minimum, the first compliance
deadline should always be stated in the NPRM and AD.‖
Implementation
TAD developed written internal procedures that outline its process for handling
compliance times. For many ADs, especially those with simple compliance times, TAD
identifies the compliance times in the regulatory text of the NPRM and the final rule AD.
For certain ADs, especially those with complex compliance times, the SB identifies the
specific compliance times and this information is incorporated by reference in the AD. In
these ADs, TAD provides a range of those compliance times (including the first and last
deadlines) in the NPRM preamble.
45
For a discussion of AD-friendly SBs see ―Agreed Principles and Practices on AD Friendly Service
Bulletins Between the Seattle Aircraft Certification Office (SACO), Los Angeles Aircraft Certification
Office (LAACO) and Boeing Commercial Airplanes,‖ dated March 31, 2006.

The FAA also issued Notice N8110.112, Placing Service Information into the FDMS,46
on September 28, 2010, to allow the FAA to post information incorporated by reference
in FAA ADs to the FDMS. Posting SBs that are incorporated by reference in final rules
will allow the public to view the compliance times in the SB. The notice also allows the
FAA to post service information documents that are proposed in an NPRM for IBR if the
DAH provides written consent.
Outcome
The ADWG’s implementation actions successfully address the AD CRT
recommendation through—
(1) TAD internal procedures for documenting compliance times in NPRMs and ADs;
(2) The FAA’s posting of service information incorporated by reference in an AD at
the NPRM stage making compliance times visible to the public as specified in
Notice N8110.112; and
(3) The FAA’s plan to include a range of compliance times in the NPRM
AD preamble for DAHs that do not provide permission to post information not
incorporated by reference or SBs at the NPRM phase.
B2.5 Harmonization
Task
―The FAA should extend the typical comment period for MCAI
[Mandatory Continuing Airworthiness Information] NPRMs. The
comment period should be extended from 30 days to 45 days, the
standard for noncontroversial FAA NPRMs. In addition, the FAA
and foreign national aviation authorities should work to harmonize
AD processes.
(AD CRT task 2 report, recommendation No. 5)
The AD CRT noted differences in NPRM comment periods between foreign (MCAI)
ADs and domestic ADs, and proposed standardizing the comment periods to 45 days.
The AD CRT also recommended that the FAA and foreign NAAs harmonize
AD processes. The ADWG noted that AD processes used among aviation authorities are
inherently different because they operate under different legislative authority. Therefore,
harmonizing AD processes is not always possible.
46
FAA Notices are temporary directives and the FAA will incorporate the information in Notice
N8110.112 into the FAA’s next revision of the AD Manual, FAA–IR–M–8040.1.

Implementation
In September 2009, TAD implemented the AD CRT proposal to standardize AD comment
periods between foreign (MCAI) and domestic ADs. Comment periods for both types of
ADs are now 45 days.
Also in 2009, TAD began to focus on working with the EASA to identify common,
legally enforceable terminology for use by both agencies in transport ADs. TAD is
currently working to share and assess the AD terminology used by both authorities and to
agree on specific standards to the maximum extent possible.
TAD also has initiated this same effort with Transport Canada Civil Aviation (TCCA) and
ANAC of Brazil to launch the same effort. Because the majority of foreign (MCAI) ADs
apply to products certificated by ANAC, EASA, and TCCA, the efforts to harmonize
with these authorities are appropriate. The FAA may consider expanding these efforts to
include other authorities in the future.
These ongoing initiatives allow changes to AD terminology to adapt to evolving

regulatory needs. These initiatives will improve working relationships and
communication among and between the FAA and other aviation authorities with
regard to ADs.
Outcome
The ADWG’s implementation actions successfully address the AD CRT recommendation
through the FAA’s extension of the comment period on MCAIs from 30 days to 45 days
and TAD’s current and future harmonization initiatives.
B2.6 Overlapping ADs

Task
Multiple ADs affecting airworthiness in the same area of the airplane
resulting in overlapping and confusing mandates for air carriers. This can
lead to inadvertent noncompliance or reversal of previous AD actions.
For situations involving multiple structural service documents and ADs,

the FAA should explore innovations in AD tracking and management (for
example, a zonal approach, where tasks are compiled covering all
AD requirements for a given area).
(AD CRT task 2 report, finding No. 4, bullet No. 1; recommendation

The AD CRT recommends tracking AD-related design changes to ensure they do not
conflict with other mandatory approved designs to avoid potential noncompliance. The
ADWG noted the DAH is in the best position to minimize the effect of multiple ADs
requiring overlapping or conflicting actions in the same area of the aircraft. Both the

regulatory agency and the DAHs should establish procedures that identify previously
issued ADs that could create overlapping and/or conflicting actions that could result in a
noncompliance before a new AD is issued.
When the DAH provides the results of its investigation of AD-related service information
in the area of the newly proposed AD action, the FAA must consider the effects of
possible overlaps or conflicts to ensure that the newly proposed AD action will not lead
to a noncompliance.
A prime objective of the FAA’s AD-friendly initiative, developed in collaboration with

operators and DAHs, is to minimize differences between the service information
provided by the DAH and the AD actions that are required to address the unsafe
condition. To achieve the objectives of both the AD-friendly initiative and the
AD CRT recommendation, the DAH must address the effects of overlapping and/or
conflicting service information during the SB development process and the FAA also
must evaluate and appropriately address those effects before the FAA drafts the AD.
Implementation
For domestic products, FAA processes have been revised to record on the AD worksheet
the list of existing ADs affecting/overlapping the newly proposed AD actions that could
lead to a noncompliance, confirm that no conflicts exist, and verify whether the DAH
confirmed this information. The new process is used to evaluate planned ADs (that is,
the process will not be retroactive). The FAA’s draft AC 20–xxx, chapter 4 explains this
process and provides best practices for DAHs to identify and avoid conflicting
requirements in AD-related SBs. The FAA plans to issue a final AC by the end of 2011.
For Airbus, Embraer, and Bombardier products, those DAHs will work with their
respective civil aviation authorities to address any conflicts or overlaps in their ADs. For
imported products, the FAA will continue to follow FAA Order 8040.5, Airworthiness
Directive Process for Mandatory Continuing Airworthiness Information, which relies on
issuance of foreign ADs before drafting and issuing FAA ADs.
Outcome
The ADWG’s implementation actions successfully address the AD CRT recommendation
by DAH/FAA implementing a system to identify overlapping/conflicting SBs/ADs that
could lead to noncompliance. The FAA changed the AD worksheet to include a section
on ADs affecting or overlapping the current AD action, confirming no conflict exists, and
identifying whether the DAH confirmed the information. In addition, the FAA
documented the DAH process as a best practice in draft AC 20–xxx, Chapter 4, Avoid
Overlapping and Conflicting SBs dated June 13, 2011. The FAA plans to issue a final AC
by the end of 2011.

B2.7 Posting Service Information
Task
Occasionally, the OEM’s service instructions are not available when the
AD NPRM is issued. In addition, copies of service instructions are not
included in the Government’s electronic regulatory docket system. In
either case, this prevents air carriers from having the full comment period
to comment on the specifics of the service document.
OEMs should review Intellectual Property and Export Compliance

policies to allow easier public access to NPRM- and AD-referenced
service instructions via the electronic regulatory docket system.
(AD CRT task 2 report, finding No. 4, bullet No. 2; recommendation

After an AD is issued, § 21.99(a)(2) requires the DAH to make available the descriptive
data for required design changes to all operators of the product. Although DAHs
typically provide this data via service information to operators before AD issuance, the
FAA does not make the information available directly to the public. Placing the service
information associated with correcting an unsafe condition in the FDMS at Web site
http://www.regulations.gov would ensure public access.
Additionally, the FAA is under scrutiny from the Office of the Federal Register (OFR) for
not making IBR material readily available. The OFR has indicated that materials that are
not readily available to the regulated public do not qualify for IBR approval under
1 CFR § 51.7(a)(4). If the FAA were not allowed to include IBR material in ADs, then
ADs would become significantly lengthy and potentially confusing because the FAA
would have to include the corrective action procedures in the AD.
Implementation
The FAA issued Notice N8110.112, Placing Service Information into the FDMS, on
September 28, 2010. This notice requires service information that is incorporated by
reference to be placed into the FDMS. For service information that is not incorporated by
reference, written consent is required from the DAH before placing the service
information in the FDMS. The Delegation & Airworthiness Programs Branch, AIR–112,
sent letters to Airbus, Bombardier, and Embraer requesting their positions for posting
service information required to address an unsafe condition at the NPRM stage into the
FDMS. Each DAH provided its position on this issue. Boeing has given its consent to
post service information at the NPRM stage that is not incorporated by reference in an
AD to the FDMS.

Outcome
The ADWG’s implementation actions successfully address the AD CRT’s
recommendation for OEMs/DAH to review intellectual property and export compliance
policies to allow easier public access to NPRM- and AD-referenced service instructions
via the FDMS. The ADWG recognizes that the proposed solution may not fully address
the AD CRT’s concern that service instructions are not available when the FAA issues
an NPRM given that a DAH’s permission is necessary to place service information
proposed for incorporation by reference in an AD into the FDMS at the NPRM stage and
it may choose to decline. In addition responses received from Airbus, Bombardier, and
Embraer state that their companies do not agree with posting AD-related service
information to the FDMS because their service information is available electronically via
their respective Web sites well in advance of the FAA publication of an AD NPRM.
However, the ADWG considers FAA issuance of FAA Notice N8110.112 to be an
acceptable solution to the AD CRT recommendation. In accordance with FAA policy, the
notice will be formally incorporated into FAA guidance, specifically the AD Manual by
September 2012.
B3.0 CONCLUSION
The ADWG successfully addressed recommendations assigned by the AD ARC. The
implementation actions discussed above meet the key objective to help ensure the
AD development process is effective and efficient. The improvements in the
AD development process are as follows:
 Addressed earlier SB credit and ex parté communications in the AD Manual in
chapter 3.
 Standardized domestic AD worksheet (May 2011) addresses potential
overlapping/conflicting ADs and credit for earlier service information.
 Standardized domestic AD template (May 2011) addresses maintenance
expectations for certain ADs and credit for earlier service information.
 Issued draft AC 20–xxx, dated June 13, 2011. The AC contains information on
ex parté communications and new processes to check for overlapping/conflicting
AD actions and use of ―later approved parts‖ in SBs/ADs. The FAA expects to
issue a final AC by the end of 2011.
 Issued Notice N8110.112, Placing Service Information in the FDMS dated
September 28, 2010. Posting service information to the FDMS removes the need
to include initial compliance times in NPRM and final rule ADs.
 Developed TAD guidance to include a range of compliance times in the NPRM
preamble for NPRMs that do not include specific compliance times in the
regulatory requirements.
 Standardized 45-day comment period for both domestic and foreign
(MCAI) NPRMs.

 Continue harmonization initiatives through TAD business plan processes.
 Developed FAA/DAH process to avoid overlapping/conflicting AD-related SBs
and ADs.

APPENDIX C—AD IMPLEMENTATION WORKING GROUP
C1.0 INTRODUCTION
The AD ARC formed the AD Implementation Working Group (AIWG) to address
AD CRT recommendations related to air carriers/operators implementing ADs and
maintaining compliance with ADs. The AIWG’s key objective is to identify and develop
air carrier guiding principles, processes, and procedures, and best practices for
implementing and maintaining compliance with ADs to ensure a safe product.
The AIWG is comprised of 18 members representing AFS, AIR, U.S. air carriers,
U.S. and foreign aircraft manufacturers, and repair stations. The AIWG met on six
occasions and held monthly and weekly teleconferences to evaluate and develop
implementation actions for its assigned recommendations. The AIWG lead tracked the
working group’s progress using project plates that contained the assigned
recommendation, the expected outcome/deliverables, and individual milestone tasks. The
AIWG lead provided status updates to the AD ARC members at the ARC meetings noting
if the working group would meet its schedule to complete its review and analysis of the
assigned recommendations or had encountered difficulties.
C2.0 ASSIGNED TASKS

The AD ARC assigned the AIWG the following seven recommendations to evaluate and
 Approval all AMOCs as global;
 CMO approval not required to implement an AMOC;
 AD Compliance—Crisis process;
 Prevent Class 2 ADs from being undone/Process or marking of AD installations.
 Maintain AD configurations—continually verify AD accomplishment, sampling
of AD projects to ensure demodification has not occurred;
 Implement training on AD process and to reinforce best wiring practices; and
 Air carrier control process.
The AIWG documented its evaluation of each recommendation and the implementation
action in a summary sheet report. The AIWG addressed the seven recommendations in
eight summary sheets. The complete unedited working papers that documented the
AD ARC’s working groups’ review, analysis, and decisions are available for viewing and
download from the AD ARC Web site at
its implementation action, and outcome are excerpted from the AIWG summary sheets
Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page C–1

C2.1 AD Installation and EWIS Training
Task
Each air carrier, OEM, and repair facility should implement training—
 On the AD process and AD implementation.
 To reinforce best wiring practices (for example, EAPAS).
(AD CRT task 1 report, recommendation No. 4, bullet Nos. 1 and 2)
The AIWG noted that any operator that is responsible for performing maintenance,
preventive maintenance, or alterations required by an AD should have processes in place
that consider the training of aviation maintenance technicians (AMTs) before
accomplishment of work. There should be a basic AD compliance training course that
establishes an awareness of the AD processes and why it is essential to properly perform
the work required by an AD and to maintain those requirements. Training of AMTs will
ensure the proper emphasis on the critical nature of potential failure modes leading to the
defined unsafe condition. In addition, AD initial compliance may be affected by a
previously installed modification, by an STC, or by other work in the area. AD-specific
training should include an assessment of the AMT’s knowledge and capability and the
awareness of the details necessary for conformity to the requirements mandated by
the AD.
For complex ADs, the operator’s training program should provide a risk assessment of
the training needs as well as ―site-specific‖ restrictions for accomplishment of particular
actions. These considerations can be used to limit the variability introduced by
accomplishment across a system and/or leverage the use of maintenance locations where
knowledgeable personnel, appropriate tooling, and other capabilities are available.
Further, before AD implementation, the operator should have a program in place to
determine, based upon a risk assessment, whether specific maintenance training is
needed. In some cases, the AD will require specific training for personnel and in those
cases the training must be accomplished and documented before AD implementation.
Complex ADs as well as those involving new wiring practices or avionics may require
specific training that is not generally available to the AMT therefore it is incumbent upon
the operators to consider the technician’s qualifications and training before assigning
tasks that have safety implications such as AD accomplishment.
The AIWG found that the 2007 EAPAS effort developed extensive training in the new
lessons learned for the design, certification, installation, maintenance, and inspection of
aircraft wire systems. The AIWG believed this is another opportunity to stress the need
for AMTs, including those working specifically for air carriers, DAHs, and repair stations
to receive wiring training that is guided by AC 120–94, Aircraft Electrical Wiring
Interconnection Systems Training Program.

Implementation
The AIWG submitted draft language for the AD management AC to the FAA addressing
the issues discussed under its review of the issue/problem above. The AIWG assumes the
ATOS EPI and SAI documents affected by the draft AD management AC will be revised
as appropriate. Although not specifically required under § 121.375, Maintenance and
preventive maintenance training program or § 121.1111, Electrical wiring interconnection
systems (EWIS) maintenance program; air carriers, DAHs, and repair stations should
have an EWIS training program in place.
Outcome
The AIWG’s proposed implementation actions successfully addresses the AD CRT’s
recommendation to implement training on the AD process, AD implementation, and best
wiring practices by operators establishing a basic AD compliance training course that
establishes an awareness of the AD processes and why it is essential to properly perform
the work required by an AD and to maintain those requirements. Guidance for operators
to establish such training is contained in AC 39–9, appendix 3 on Air Carrier Training.
The appendix provides best practices for reinforcing AD awareness and the development
of skill-specific training such as NDT and EWIS. In addition, the FAA has revised the
EPIs and has issued a temporary revision to the SAIs to reflect the guidance in AC 39–9.
C2.2 Air Carrier AD Compliance Process

Task
 ATA should review the primary elements for air carrier internal compliance
planning discussed above and disseminate like information to the industry.
(See discussion of the Lead Airline Process under section 2.2.2 AD Development,
AD CRT Task 2 report.)
 The FAA and ATA jointly should develop a policy for CMO participation during
the air carrier’s AD compliance planning process. CMO participation during the
process will educate the ASIs on the air carrier’s AD compliance plan
recommendations. However, the CMO should not perform a quality control
function or require a signoff. Currently, FAA PIs are invited to reliability board
meetings at some air carriers but otherwise are not involved in developing EAs47.
The intent of advance CMO participation is to remove the need for AMOCs and
reduce paperwork violations and infractions.
 CMOs should participate in AD prototyping. However, this monitoring should
not require a signoff from the CMO or be a required step to completing any work.
(AD CRT task 2 report, recommendation No. 6, bullet Nos. 2, 3, and 4)
47
Engineering authorizations.

Based on the strict interpretation of AD compliance, the industry has developed best
practices to help with consistent implementation of AD-related actions. For this reason, it
is important to identify the following through air carrier manuals and FAA guidance
material and policy: (1) the elements for effective AD compliance planning and
implementation; (2) the specific associated processes and tasks that comprise these
elements; and (3) the individuals with authority and responsibility for the elements.
In addition, ASIs are often not familiar with operators’ AD compliance plans, which can
raise questions and concerns as to how an operator is complying with a particular AD.
Having ASIs participate in the operator’s AD planning process will give the ASI the
opportunity to comment on any potential compliance issues, as well as provide the
ASI opportunity to offer guidance and suggestions. ASI participation is not mandatory.
As such, the draft documentation will advise that it is a best practice to invite the local
FAA to the operator’s compliance planning meeting.
ASIs also are not always familiar with what is involved in accomplishing AD tasks.
ASI participation in the prototype process fosters a culture of open and honest
communication with the goal of improving continued operational safety.
Implementation
The AIWG proposed to develop industry best practices for operators to follow in
response to ADs. The AIWG’s implementation plan includes pre-planning,
implementation, and AD verification programs. These best practices also include
ASI and CMO participation in AD compliance planning and on-aircraft prototyping.
The FAA incorporated the AIWG’s suggested wording into AC 39–9. The AIWG also
proposed language for FAA Order 8900.1 to identify the ASI’s role in the air carrier’s
AD compliance planning process. The FAA incorporated the AIWG’s suggested wording
in FAA Order 8900.1.
The AIWG also recognized that upon issuance of AC 39–9, the FAA will revise the EPI
and SAI DCTs to include a reference to the new AC for industry best practices. Revision
of the EPI and SAI DCTs will encourage operators to use these practices and the AC and
promote an industry standard method of processing ADs to comply with the
applicable regulations.
Outcome
The AIWG’s proposed implementation actions successfully address the AD CRT’s
recommendation to develop policy for CMO participation during the air carrier’s AD
compliance planning process and AD prototyping. The FAA issued AC 39–9 that
includes appendix 1 on Air Carrier Compliance Planning that provides focus areas for
consideration during the AD compliance planning process and includes guidance to invite
the CMO or Flight Standards District Offices (FSDO) to attend the operator’s final
document review meeting as part of the AD compliance coordination phase.

In addition, the AC includes appendix 4 on Air Carrier Prototyping to help ensure the
accuracy of the implementation document. Appendix 4 contains best practices on silent
prototyping, prototyping roles and responsibilities, feedback, outbrief meetings, and
support systems to address technical concerns.
The FAA also issued a section on Evaluating an Airworthiness Directives Management

Process in FAA Order 8900.1 that states an operator may request/invite ASIs to the
AD planning meeting. Thus, the operator may develop a process for notifying and
inviting its CHDO/ PI or local FSDO prior to AD planning meetings.
A [Change] notice to AC 39–9 and Order 8900.1, chapter 58 also more directly discusses
ASI participation in operator prototyping activities.
AC 39–9 also contains an extensive discussion of the primary elements for air carrier
internal compliance planning. This indirectly addresses the AD CRT recommendation for
ATA to review the primary elements for air carrier internal compliance planning
discussed above and disseminate like information to the industry as the AC targets the
AD management process for industry. ATA also will reference AC 39–9 in ATA
Specification 111. See discussion in section 2.6.1 of this report.
Finally, the FAA has issued updated EPI and SAI DCTs in either temporary or final form
incorporating the AD process improvements.
C2.3 All AMOCs Global

Task
The FAA and industry should develop a process to approve all AMOCs
as global unless the requesting air carrier specifically states that it does
not want the AMOC shared. The global AMOCs would be posted on
OEM Web sites accessible to all air carriers in a way that protects the
intellectual property rights of the OEMs and the air carriers where
appropriate. The industry and the FAA also should ensure that CHDOs
do not require air carriers to gain their approval to implement a
global AMOC.
(AD CRT task 2 report, recommendation No. 9, issue 1)
The AD CRT task 2, recommendation 9 consists of two separate recommendations:
(1) approving all AMOCs as global and posting these on a Web site for ease of
accessibility to all air carriers and (2) clarify the role of the ACO and the PI (principal
maintenance inspector (PMI) or principal avionics inspector (PAI)) in AMOC approval
and implementation. The AIWG addresses the first part of the recommendation in
this section.

There was a strong consensus within the AIWG that it is impracticable to approve all
AMOCs as global because most AMOC requests address unique configuration issues or
situations for specific serial number aircraft that would not be applicable to other aircraft.
However, all requests that have general applicability should be reviewed to determine
whether a global AMOC can be issued.
FAA Order 8110.103, Alternative Methods of Compliance defines a global AMOC and
the AMOC approval process. A global AMOC applies to two or more air carriers and is
used to obtain approval for multiple serial numbers or makes and models as specified in
the AD. The AMOC approval process, whether for a single aircraft or for a fleet, allows
anyone to request an approval from the FAA. Once compliance has been shown, the FAA
issues the approval. In practice, the vast majority of AMOCs are approved by DAH
delegated organizations or personnel within the DAHs. Of the AMOCs submitted
directly to the FAA, a majority come from the DAHs for items they are not delegated to
approve but are reviewed by delegated personnel with a recommendation for approval.
The remaining requests typically come directly from air carriers or aircraft owners.
In reviewing the requests, the FAA determines if the AMOC addresses the unsafe
condition and demonstrates compliance with the applicable regulations. Often this
demonstration includes design data, analysis, and validated inspection methods that may
be considered proprietary information by the requestor. Global AMOC requests must
account for the fact that there may be many different configurations. Every global
AMOC proposal must be compatible with every aircraft covered under the AMOC.
Because in most cases the DAHs have the design data for each individual configuration,
they are in a unique position to determine the need for and often request global AMOCs.
In fact, the vast majority of global AMOCs are issued to the DAHs. As both the
requestor and holder of the global AMOC, the DAH is best suited to making this
information available to its customers and has an incentive to do so.
If several different air carriers submitted similar requests for AMOCs directly to the FAA
with the necessary substantiating data, the FAA will issue an AMOC individually to each
of those air carriers. However, to make a determination of whether a global AMOC can
be issued for that same issue, the FAA would need to know if there are other
configurations of that design in the field. The FAA does not have this data readily
available and does not have the resources to obtain and interpret the data. The FAA
typically relies on the DAH to conduct this analysis and then makes a determination
based on the DAH’s request and the data presented. If an air carrier or other party
requests the global AMOC, it would be incumbent on the requestor to demonstrate
applicability for the entire fleet. If this has not been demonstrated, the FAA does not
have the resources to make this finding

The AIWG considered many options in developing solutions and noted there are legal
issues associated with sharing of proprietary data among the air carriers, FAA, original
equipment manufacturer (DAHs48), and other requestors for AMOCs.
Implementation
The AIWG solutions include a shared implementation approach where the air carriers,
DAHs, and FAA have responsibility in expanding the use of global AMOCs.
FAA Policy Memo.

(1) Document DAHs best practice of implementing a formal process to review all
AMOC requests as candidates for issuance as global AMOCs when applicable. The
criteria for the formal process review of AMOC requests should include the following:
review each AMOC request as a candidate for global, including requests for the same
AMOC from two different air carriers, and review AMOCs issued by the ACO for
possible global AMOC candidates. The FAA Policy Memo will also document
DAHs best practice of posting global AMOCs on their respective Web sites and provide
periodic notifications of their release. The memorandum includes the type of information
to be posted.
(2) Document ARSA, ATA, and RAA best practices of posting links to DAH Web sites.
AC 39–9, Airworthiness Directives Management Process. The FAA included in the new
AC on AD Management a section recommending air carriers include statement
permitting the FAA to share the subject of the request with the DAH or to use the
information to issue a global AMOC. The AC also recommends air carriers include
language in their AMOC request letters to the DAHs that permits the DAHs to use
air carrier fleet AMOC requests as the basis for requesting a global AMOC. The FAA
published AC 39–9 on June 1, 2011.
FAA Order 8110.103, Alternative Methods of Compliance. The FAA revised

Order 8110.103 to create a new paragraph 4–3 f, Sharing AMOC, Requests with DAHs.
This paragraph requires the FAA AMOC approving office to provide the DAH a list of
the AMOCs requests that have included permission to be shared. The DAH’s global
AMOC database allows air carriers to search previously approved AMOCs that may
apply to their aircraft. To assist DAHs in identifying AMOCs that might be candidates
for a global AMOC, air carriers may include a statement in the AMOC request letter that
permits the approving ACO or directorate office to share the subject of the AMOC with
the DAHs. The approving office will periodically share with the DAH the subject of all
AMOC requests that include the following permission statement; ―Air carrier XYZ grants
the FAA approving office permission to share the subject of this AMOC request with the
DAH for the article or product for their consideration in asking the FAA to issue a global
AMOC for on this subject.‖
48
DAH as used in this section it is intended to refer to manufacturers of transport airplanes and the engines
installed thereon. It is assumed that some small business DAHs might not have the same capabilities as
larger businesses such as engineering departments.

Outcome
Although the AIWG found it unfeasible to make all AMOCs global, the
AIWG’s implementation actions successfully address the first part of the
AD CRT recommendation by expanding the use of global AMOCs and having DAHs
post global AMOCs on their Web sites and provide notification to subscribers of their
release. In addition, in place of a policy memo, the FAA issued draft AC 20–xxx to
include section 5–2, Sharing AMOC Proposals which contains a statement for operators
to provide permission to DAHs to make an AMOC global and section 5–4, Posting
Global AMOCs on Web site. The FAA also revised FAA Order 8110.103 [CHG 1] and
AC 39–9 [Change 1] as noted above to support the expanded use of global AMOCs.
Although the FAA decided it would not address the best practice of associations posting
links to DAH Web sites in its guidance, ARSA, ATA, and RAA may post links to
DAH Web sites on their respective association Web sites.
C2.4 ASIs and AD Prototyping

Task
The ATA should add to ATA Specification 111, or develop a new
specification to address (upon adoption of an AD) AD compliance
planning that includes the following industry guidelines:
 Invite the ASI to air carrier compliance planning sessions and
AD compliance prototyping for better understanding of issues.
 Ensure the accuracy and clarity of the engineering order (EO) or other
implementation document. The air carrier should consider silent
prototyping where a technician prototypes the EO without verbal or other
assistance.
 Augment air carrier compliance planning with an
AD verification program.
ASIs are often not familiar with operators’ AD compliance plans, which can raise
questions and concerns as to how an operator is complying with a particular AD. Having
ASIs participate in the carrier’s AD planning process will provide ASI visibility of any
issues with complying with the AD, the plan for accomplishment, as well as provide them
the opportunity to provide guidance and offer suggestions to facilitate compliance.

Compliance documents are sometimes difficult to understand or can contain errors that
are not detected during the paperwork review. An on-aircraft prototype of the work
instructions would ensure accuracy of the instructions and the ability to accomplish the
work as written. This is an actual prototype of the air carrier’s implementation document
that resides outside of the ATA Specification 111 service instruction prototyping process.
The ATA Specification 111 prototype may not capture all of the specific issues, concerns,
or configurations that an air carrier may experience. Some ADs are capable of being
undone during normal maintenance activities. Consideration to how an AD can be
undone, or continued verification of configuration, should be included in the
AD compliance planning process.
Implementation
The AIWG proposed to develop industry best practices for operators to follow in
response to ADs. The implementation plan includes pre-planning, implementation, and
AD verification programs, as well as prototyping of the work instructions. Prototyping
the work instructions will ensure that the instructions are clear and compliant and can be
repeated. The AIWG expected this suggested wording be incorporated into a new AC on
AD management.
The AIWG recognized that upon issuance of the proposed AC, the FAA will revise the
EPI and SAI DCTs to include reference to the new AC for industry best practices.
Revision of the EPI and SAI DCTs will encourage the use of these practices and the AC
and promote an industry standard method of processing ADs to comply with the
applicable regulations.
The AIWG also proposed to develop language for FAA Order 8900.1 to identify the
ASI’s role in the air carrier’s AD compliance planning process. The suggested wording is
intended for incorporation in a revision to FAA Order 8900.1, or into a policy letter for
ASIs. The AIWG assumed that the FAA may not always attend the AD compliance
planning meetings or prototypes when invited.
Outcome
recommendation to develop policy for CMO participation during the air carrier’s
AD compliance planning process and AD prototyping. The FAA issued
AC 39–9, Airworthiness Directives Management Process which includes Appendix 1
Air Carrier Compliance Planning that provides focus areas for consideration during the
AD compliance planning process and includes guidance to invite the CMO or FSDO to
attend the operator’s final document review meeting as part of the AD compliance
coordination phase.

In addition, the AC includes Appendix 4 Air Carrier Prototyping to help ensure the
accuracy of the implementation document. Appendix 4 contains best practices on silent
prototyping, prototyping roles and responsibilities, feedback, outbrief meetings, and
support systems to address technical concerns. The AC also contains development of an
AD verification process as part of the planning phase. Appendix 5 contains the specifics
for establishing a sampling program to identify ADs that require verification.
In addition, the FAA issued a section titled Evaluating an Airworthiness Directives

Management Process in FAA Order 8900.1 which states an operator may request/invite
ASIs to the AD planning meeting.
AC 39–9, Change 1 and Order 8900.1, chapter 58 also more directly discuss
ASI participation in operator prototyping activities. The FAA also has issued
updated EPI and SAI DCTs in either temporary or final form incorporating the
AD process improvements.
Finally, ATA has revised ATA Specification 111 to reference AC 39–9. See discussion
under section 2.6.1 of this report.
C2.5 CMO Role in AMOC Process

Task
The FAA and industry should develop a process to approve all AMOCs
as global unless the requesting air carrier specifically states that it does
not want the AMOC shared. The global AMOCs would be posted on
OEM Web sites accessible to all air carriers in a way that protects the
intellectual property rights of the OEMs and the air carriers where
appropriate. The industry and the FAA also should ensure that CHDOs
do not require air carriers to gain their approval to implement a
global AMOC.
(AD CRT task 2 report, recommendation No. 9, issue 2)
The AIWG discussed that the lack of clarity of the PI’s role does not appear to be as
pervasive as the AD CRT recommendation indicates. However, the AIWG found there is
an opportunity to improve awareness and guidance addressing PI’s s role in the
AMOC process.
AFS has no published guidance material for use by its ASIs that defines their role in the
process. FAA Order 8110.103A is primarily written for ―Aircraft Certification Service
Personnel responsible for AMOCs.‖

The intent of § 39.1949 is for the PI to be aware of the request so that appropriate
information can be provided to the ACO that will approve the request. The PI is to be
notified but not approve the request. The PI should provide comments to the
ACO regarding information such as the requestors’ fleet configuration, operational
impact, environment, or maintenance practices that might be useful to the ACO in
evaluating the request.
Many air carriers request technical support from the DAHs. DAHs often obtain third
party AMOCs from the ACOs on behalf of the air carriers. Sometimes these AMOCs are
serial number specific and other times they are global (that is, they apply to the entire
fleet). Air carriers must notify their PI (PMI or PAI) of these AMOCs prior to use but no
further approval is required from the PI.
Some air carriers complain that they are required to receive PI approval before
implementing an AMOC. Some air carrier’s general maintenance specifications may
include language requiring PI approval. In this case, PI approval would be required;
however having PI approval included in general maintenance manuals is not a regulatory
requirement.
There is an industry-wide perception that PIs are not standardized in their interpretation
of the approval/notification requirements of § 39.19 and their role in the AMOC process.
Implementation
 Increase PI’s awareness and understanding of their role in the AMOC process
through a series of regional briefings. The FAA completed regional briefings in
June 2010 and included a slide in its presentation to directly address this issue.
 Create language in FAA Order 8900.1 providing guidance on the PI’s role in the
AMOC process. This change is intended to establish policy for future training
and use by FAA field inspectors.
 Reword ATOS SAI 1.3.6 (reference Question 1.8) ―FAA approval‖ to
―FAA approval by the manager of the FAA office identified in the AD.‖
Outcome
recommendation to ensure that CHDOs do not require air carriers to gain their approval
to implement a global AMOC. The FAA issued AC 39–9, Airworthiness Directives
Management Process which states the AD identifies the responsible ACO/ECO that
approves/disapproves AMOC proposals. In addition, the FAA issued chapter 59 to
FAA Order 8900.1 that states the PI may add comments to the AMOC proposal, but
cannot approve/disapprove it. The PI must forward a copy of the AMOC proposal to the
manager of the FAA office identified in the AD, or its delegated representative.
49
14 CFR § 39.19 defines alternative methods of compliance (AMOCs) to ADs and how these are to be
transmitted to the FAA. In general, it requires requestors to either submit it directly to the principle
inspector (PI) for comment and transmittal to the appropriate Aircraft Certification Office (ACO) or the
AMOC request can be transmitted to the PI and the ACO simultaneously.

In addition, the FAA completed regional briefings on the ASI role in the AMOC process
at various locations throughout the United States from January through June 2010.
Note: The FAA will publish updated EPI and SAI to match any FAA guidance during its
next publication cycle in September 2011.
C2.6 Communication and 24/7 AMOC Process

Task
Responsive communication and industry collaboration are essential in
crises involving widespread AD compliance issues affecting air carriers.
The ACO and OEM should develop contingency procedures and
disseminate them internally in advance of future events. This will ensure
that points of contacts are established for air carrier use in expediting
resolution of fleet wide issues. The ATA may facilitate this process if
air carriers immediately advise the ATA of a significant compliance issue
that may be widespread and newsworthy.
This issue relates to the interaction among air carrier, DAHs, AEG and ACO at different
levels. Communication needs to occur at the first sign that there may be a noncompliance
that affects multiple aircraft and should take place within the different entities with the
right escalation level.
The FAA has developed an internal 24/7 process that can be invoked by AFS personnel
including when ACO support is needed after hours. The AR–ANM–029–W2 published
in December 2009 includes a path for air carrier or CHDO contact of the ACO.
All major DAHs provide 24/7 technical support to their air carriers including points of
contact. This support should include a crises escalation process that facilitates the
involvement of the air carrier, the PI (either PMI or PAI) and the ACO.
Implementation
FAA work instruction AIR–ANM–029–W2, establishes 24/7 urgent AMOC request
process for ACO internal support to CHDO and the FAA briefed CHDOs on the process.
All DAHs have a technical helpdesk to ensure 24/7 support to air carriers to prevent
groundings due to potential AD noncompliance. Air carriers have an existing means to
initiate contact with both the CHDO and the DAH’s technical helpdesk. Air carriers
should establish and use contact points with the DAHs before the issue becomes a crises.

The air carrier and FAA Regional Office, as a best practice, should jointly develop an
issue resolution process. For compliance issues, this process may include communication
first with the DAH and then as necessary with the AEG and ACO through the PI. The
practice also should include an escalation contingency plan. The communication process
should include a risk management/safety assessment for resolution purposes for aircraft
and possibly fleet wide issues.
The new AD Management AC being developed by AFS–300 through the AD ARC

working groups includes language recommending air carriers develop a conflict
resolution process with their FAA Regional Office and includes a risk management/safety
assessment process. This process should ensure that the air carrier and the PI mutually
understand that the purpose of the FAA internal 24/7 process is for the PI to communicate
with the AEG and ACO on significant compliance issues.
In a new FAA AD Policy Memo, include language recommending OEM/DAHs put a

process in place or document existing process to ensure 24/7 support to air carriers to
prevent grounding due to potential AD noncompliance.
In the new AD management AC, include language recommending that ATA-member

air carriers invoke the provisions of the ATA Specification 111 for a significant
compliance issue that may be widespread and newsworthy. Other associations (such as
ARSA and RAA) should establish a similar process. The AC should include language
regarding ATA and other air carrier associations’ coordination with regulatory authorities
and OEM/DAHs. Air carriers should establish and use contact points with the
OEMs/DAHs before the issue becomes a crises.
Outcome
The AIWG’s proposed implementation actions successfully addresses the AD CRT’s
recommendation to recognize that responsive communication and industry collaboration
are essential in crisis situations involving widespread AD compliance issues affecting
operators. The FAA issued AC 39–9, Change 1, Airworthiness Directives Management
Process which states as part of the operator’s/air carrier’s AD management process, it is
recommended that the operators/air carriers develop a process to coordinate
AD compliance matters with the local FAA office. This process may reference a conflict
resolution process for circumstances needing immediate resolution. Before agreeing with
an operator’s/air carrier’s process, the FAA local office will ensure that the FAA’s role, as
defined in the process, is consistent with FAA policy. In addition, the AC suggests
air carriers that are members of industry associations consider using established processes
such as ATA Specification 111 or similar processes developed by other associations, for
significant compliance issues that may be widespread and newsworthy. This could
include coordination with associations, regulatory authorities, and OEMs/DAHs.
In place of a policy memo, the FAA issued draft AC 20–xxx, which includes a section on
24/7 AMOC support. The section specifies to help prevent grounding aircraft due to
potential AD noncompliance by an air carrier, a DAH should develop a process for
24/7 support. AC 39–9 also includes a discussion of 24/7 AMOC support in appendix 1
to the AC.

Note: In AC 39–9 Change 1 the FAA deemed the FAA local office as the appropriate
point of contact for conflict resolution issues instead of the FAA Regional office.
C2.7 Maintaining AD Configurations

Task
Each air carrier should develop processes and procedures to prevent
class 2 ADs from being undone during normal maintenance actions.
Each air carrier should develop processes and procedures to ensure

AD configurations are maintained.
The Team recommends the following related to AD development:

Air carriers must have a process in place to continually verify
AD accomplishment.
Air carriers should develop practices to address normal maintenance or

other actions that could possibly demodify an AD configuration,
particularly class 2 ADs. These could include the following:
Process enhancements or physical marking of AD installations for
nonstructural ADs. This alerts mechanics to the presence of an
AD installation in the area where they are working.
Air carriers should develop practices to address normal maintenance or

other actions that could possibly demodify an AD configuration,
particularly class 2 ADs. These could include the following:
Quality assurance sampling of AD projects to verify the correct setup,
and/or a sampling program that physically verifies that de-modification
has not occurred.

Class 2 ADs as defined by the AD CRT are very prescriptive; there is a high risk that
subsequent maintenance may inadvertently create an unintentional alteration from the
mandated condition or configuration where the creation of the non-compliant condition is
more likely to occur if the AMT is unaware of the AD requirements. This possibility is
particularly troublesome when the DAH’s manuals do not reflect the AD-mandated
condition or configuration. For example, a SWPM that no longer reflects how a
particular area of the aircraft must be wired.
Unless process enhancements are provided to ensure configurations are maintained,

AMTs working near AD installations with a high risk of unintentional alteration any time
after the AD is implemented may inadvertently deconfigure the AD installation by
employing standard maintenance practices. This condition may be more difficult to
detect if the AD does not contain a repetitive inspection requirement or if the area is not
inspected according to an associated maintenance program work card.
Unless there is a method of continually verifying ADs (such as re-verification at

maintenance check visits), multiple ADs in the same area, then overlapping and
confusing AD mandates and subsequent maintenance performed over the years may
result in inadvertent unintentional alteration of an AD. This may be made worse by work
instructions that can inadvertently omit detailed AD requirements that are needed to
ensure continued AD compliance.
Some planning processes may not include an AD Compliance Control Board meeting or
equivalent where predefined potential actions are reviewed and confirmed; this may
make them more susceptible to AD noncompliance issues. This AD board or equivalent
meeting would consist of all affected departments (engineering, planning, quality
assurance/quality control, the AD group, and other affected work groups) that are
responsible for ensuring AD implementation and compliance. It is during this meeting
that the risk of unintentional alteration should be discussed, and specific inspections that
must be accomplished as related to § 39.1150 must be discussed with appropriate
mitigation strategies determined, which may include, but may not be limited to,
additional process enhancements or the potential physical marking of ADs in the area.
Implementation
The AIWG’s recommendation includes the following process enhancements as measures
of alerting the AMTs of any installed ADs that could affect a task.
 Ensure design changes by DAHs associated with ADs are appropriately
incorporated in the DAH’s ICA so that the required configuration or corrective
action is universally applied.
 Add notifications to the air carriers’ manuals (AMM, CMM, and work cards).
The AD requirements should be added to the air carrier’s manuals before approval
and issuance of the AD compliance work cards.
50
§ 39.11 What actions do airworthiness directives require?

 Verify AD compliance by virtue of previously accomplished SBs (or other service
instructions contained in an NPRM) is in accordance with the
final AD requirement.
 Determine the need for specific labor classification/skills (for example, avionics,
structures, NDT, and/or aircraft engines), or limiting variation by using a ―center
of excellence,‖ or using other methods of ensuring continued AD compliance
where an uninformed or unqualified AMT, performing other maintenance in the
area, may inadvertently take the aircraft out of the mandatory compliance.
One process enhancement includes updating and adding notifications and cautions to the
air carriers’ manuals (AMM, CMM, and work cards) under § 43.13(c). This allows the
air carrier to address the ongoing compliance issues with the AD concern according to the
applicable ICAs. For certain newer ADs, ICAs are provided by the DAH under
§ 121.1109 (supplemental inspections), § 121.1111 (EWIS maintenance program), and
§ 121.1113 (fuel tank system maintenance program). These are examples of current
ICA requirements for changing conditions.
Part 21, subpart C further requires that all changes to design be approved and the FAA
should not approve a design change that results in an AD without requiring a subsequent
change to or creation of the ICA (as required by § 21.50) that ensures the AD mandates
are continued after the original modification or action to address the unsafe condition.
When the DAH references ICA revisions or sections in the SB that are incorporated by
reference in an AD, the air carrier should evaluate whether revision to its maintenance
program is necessary to prevent inadvertent AD unintentional alterations. In accordance
with §§ 21.50, 25.1529, and 25.1729 and appendix H to part 25, the DAH is required to
provide ICAs for the type design and changes to the type design. If applicable, the
air carrier should verify that an ICA/AWL, because of an AD, is incorporated into the
air carrier’s AD sampling (re-verification) program when the air carrier determines that a
high risk of unintentional alteration is noted during an assessment of the new AD.
The AIWG determined class 2 ADs refers to ADs having a high risk of noncompliance
through the course of normal maintenance. Factors that may identify a high-risk AD are
unintentional alteration to include actions in areas that are frequently maintained,
serviced, or exposed to elements; and particularly if the installed or new AD is a
workmanship-intensive modification or components that are frequently repaired.
The AIWG proposed that another method of detecting potential AD noncompliance

would be a sampling (AD re-verification) program. Using a process audit procedure
during scheduled maintenance visits can be an effective method of monitoring continued
AD compliance. Although the AIWG views AD sampling as a separate program from
CASS AD handling (see AC 120–79A), the air carrier can take advantage of elements of
the CASS audit method where it addresses ADs under § 121.373 for the AD sampling
program. Further, the AD sampling (re-verification) program should verify that targeted
ADs (those ADs assessed and included in the air carrier’s sampling program) are
appropriately evaluated, accomplished, and tracked and that any ADs that have been
reconfigured are appropriately evaluated for compliance along with other modifications

in the affected area. The AIWG agreed that a risk assessment is applicable for future ADs
that include ICA/AWL content and, after review by the air carrier (during AD compliance
planning), those ADs determined to have above-average risk may be included in the air
carrier’s AD sampling (re-verification) program.
The AIWG determined that each new AD should be evaluated for risk of future
noncompliance using SMS principles as applicable in AC 120–92A, Safety Management
Systems for Aviation Service Providers. An air carrier’s valid risk assessment upon
implementing each new AD should include crafting and implementing preventive
measures to eliminate and/or reduce the severity and/or frequency of unintentional AD
alteration. Further, practical risk management should include a program to ensure that
potential hazards that could result from implementing a new AD are identified and
controlled. A safety assurance program should be implemented by the air carrier to
evaluate the continued effectiveness of control strategies, and there should be a program
implemented that supports the identification of new potential hazards. One component of
such AD risk management program is the AD sampling program.
To ensure continuing AD compliance, each air carrier should add these AD handling best
practices into their AD management programs in a timely manner.
Outcome
The AIWG’s implementation actions successfully address the AD CRT recommendations
for maintaining AD configurations through the FAA’s issuance of AC 39–9,
Airworthiness Directives Management Process. The AC includes guidance on ICA,
changes to manuals, AD-referenced service instructions that have already been
accomplished, determining the need for training and specific skills, AD sampling
(including the use of CASS) and AD verification, and the use of SMS principles in
AD risk assessments for future noncompliance.
In addition, draft AC 20–xxx, Chapter 6, Maintaining Airworthiness, section 6–6,

Flagging procedures provides guidance to DAH on placing notifications in air carriers’
manuals (AMM, CMM, and work cards) that are only visible to the DAH to identify data
directly related to an AD. These flagging procedures prevent inadvertent modification of
AD-related data by the DAHs.
C2.8 Prototype ADs, Work Done Prior to AD

Task
Each air carrier should develop processes and procedures to—
 Prototype ADs before accomplishment.
 Ensure that when incorporating an SB anticipated to become an AD that
the physical condition of prior work is reviewed when the AD is issued.
(AD CRT task 1 report, recommendation No. 3, bullet Nos. 1 and 4)

There is no standard process for air carriers to prototype AD documentation. During
accomplishment of AD mandated work instructions, questions can arise due to errors in
service instructions, differing air carrier processes, obsolescence of parts, and other
challenges. This can lead to misinterpretation of the AD requirements, inconsistent
accomplishments, and deviation from the original intent of the mandated instructions. By
accomplishing a prototype of the AD compliance documentation, these issues can be
identified and resolved before accomplishing the instruction on multiple aircraft.
When service instructions that become mandated are accomplished before there is an AD,
there needs to be verification that the work accomplished meets the AD requirements.
Air carriers have processes for substitution of materials and alternate processes that could
have been used that may not be acceptable for compliance with the AD. Without
reviewing what was accomplished previously, it cannot be determined that the work
accomplished meets the requirements of the mandate.
During accomplishment of AD-mandated work instructions, questions can arise due to

errors in service instructions, differing air carrier processes, obsolete parts, and other
challenges. This can lead to misinterpretation of the AD requirements, inconsistent
accomplishments, and deviation from the original intent of the mandated instructions. By
accomplishing a prototype of the AD compliance documentation, these issues can be
identified and resolved before accomplishing the instructions on multiple aircraft. This
prototype refers to an actual prototype of the air carrier’s AD implementation document.
Implementation
The AIWG noted the prototype of the AD compliance determination is performed outside
of the ATA Specification 111 service instruction prototyping process because that
prototyping may not capture all of the specific issues, concerns, or configurations that an
air carrier may experience.
The AIWG’s implementation plan assumed the air carrier has an organizational structure
that supports a prototype process and reviews of compliance documentation. The AIWG
developed industry best practices that incorporated language to identify an
AD management process and prototyping air carrier AD implementation documentation.
The document also incorporated text that provides best practices in handling service
instructions that are accomplished before the existence of an AD. The FAA incorporated
the suggested language into a new FAA AC on AD management process.
Outcome
The AIWG’s implementation actions successfully address the AD CRT recommendations
through the FAA’s issuance of AC 39–9, Airworthiness Directives Management Process
which addresses air carrier prototyping of ADs to include silent prototyping (appendix 4)
and operator actions accomplished before the release of an AD (appendix 1).

C3.0 CONCLUSION
The AIWG successfully addressed each recommendation assigned by the AD ARC. The
implementation actions discussed above provide processes, procedures, and best practices
for implementing and maintaining AD compliance. The improvements for implementing
ADs and maintaining AD compliance for air carriers/operators are as follows:
 Established guidance in AC 39–9, Airworthiness Directives Management Process,
Appendix 3, Air Carrier Training, for operators to provide a basic AD compliance
training course that establishes an awareness of the AD processes and why it is
essential to properly perform the work required by an AD and to maintain those
requirements and the development of skill-specific training such as NDT
and EWIS.
 Developed industry best practices for operators to follow in response to ADs
including providing guidance on the AD management process to include six basic
elements: planning, support, provisioning, implementing, recording, and auditing.
See AC 39–9.
 Expanded the use of global AMOCs through shared implementation among
DAHs, FAA, and operators to review all AMOCs as potential candidates for
issuance as global AMOCs and share the AMOC approval response.
 Established posting of global AMOCs on DAH’s Web sites.
 Developed practices for CMO/FSDO participation during the air carrier’s
AD compliance planning process and AD prototyping.
 Established guidance for the CMO/FSDO role in the AMOC approval process in
FAA Order 8900.1 and AC 39–9.
 Provided guidance in AC 39–9 Change 1 on operator’s establishing a conflict
resolution process on AD compliance issues with its local FAA office.
 Provided guidance in AC 20–xxx for DAHs to develop a 24/7 support process to
help prevent aircraft groundings due to potential AD noncompliance.
 Addressed best practices for maintaining AD configurations through AC 39–9 to
include—
o Ensuring AD design changes are incorporated in ICA;
o Adding AD requirements to manuals;
o Addressing AD-referenced service instructions that have already
been accomplished;
o Determining the need for training and specific skills;
o Conducting AD sampling (including the use of CASS) and AD verification;
o Conducting AD prototyping (including silent prototyping); and
o Using SMS principles in AD risk assessments for future noncompliance.

APPENDIX D—FAA ORGANIZATION/PROCEDURES
WORKING GROUP
D1.0 INTRODUCTION
The AD ARC formed the FPWG to address AD CRT and IRT recommendations related to
AD compliance issues. The FPWG’s key objective is to define decisionmaking processes
for compliance versus noncompliance that can be used by the FAA and aviation industry
in any situation.
The FPWG is comprised of 19 members representing AFS, AIR, FAA Regional Counsel,
U.S. air carriers, U.S. and foreign airplane manufacturers, and repair stations. The
FPWG held monthly meetings and teleconferences to evaluate and develop
implementation actions for its assigned recommendations. The FPWG support staff
tracked its progress using project plates that contained the assigned recommendation, the
expected outcome/deliverables, and individual milestone tasks. The FPWG lead
provided status updates to the AD ARC members at the ARC meetings noting if the
working group would meet its schedule to complete its review and analysis of the
assigned recommendations or had encountered difficulties.
The FPWG and its support staff also served as the focal for coordinating the update
and/or development of any FAA policy and guidance developed by the AD ARC working
groups as part of an implementation action, and steering any policy and/or guidance
through the FAA approval and publication process.
D2.0 ASSIGNED TASKS

The AD ARC assigned the FPWG the following 27 recommendations from the AD CRT
and IRT reports (includes primary recommendations and associated sub-issues) to
evaluate and analyze:
 Develop decisionmaking process for determining compliance
versus noncompliance;
 Reemphasize to ASIs that they have the authority to use professional judgment to
determine whether noncompliance exists;
 Develop a decision tool when making compliance determinations;
 Streamline and improve the process for making compliance determinations;
 Eliminate single-person decisionmaking;
 Clarify the roles and responsibilities of AFS, AIR, manufacturers, and the
air carrier in the compliance decisionmaking process;
 Ensure that AEG personnel are included in the AMOC process
 Develop an escalation process to raise ASI concerns on
compliance determinations;
Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page D–1

 Define and strengthen the communication process flow;
 Strengthen the role of the AEG;
 Revise the ATOS guidance material for ASIs;
 Establish a formal policy on how to handle issues where compliance is unclear;
 Ensure FAA field offices have a direct link to the AEG;
 Charter a working group to strengthen the AMOC process;
 Communication channels—AMOC process;
 Simultaneous coordination of an AMOC with the ACO and the CMO;
 ACO expeditiously receives concurrence from AEG on the AMOC,
and AEG advises CMO;
 Delegation of AMOCs to designated engineering representatives (DER)
and authorized representatives (AR);
 Delegation of AMOCs to other ACOs;
 Staff availability on a 24/7 basis (ACO, AEG, and CMO);
 ASIs should not be required or expected to conduct any type of risk-assessment
before taking action on AD noncompliance;
 Develop further guidance and training to assist FAA in
determining noncompliance;
 Develop a formal policy regarding ASI decisionmaking;
 Develop a decisionmaking flowchart as a guide for ASIs making
compliance determinations;
 Review §§ 39.7 and 39.9, and, if necessary, revise those sections to clarify that
AD compliance;
 The FAA should retain the right to ground any airplane not in compliance with an
applicable AD. ASIs should not be required/expected to conduct any type of
risk-assessment before taking action AD noncompliance; and
 The FAA’s role in AD compliance planning.
The FPWG documented its evaluation of each recommendation and the implementation
action in a summary sheet report. The FPWG addressed the 27 recommendations in
5 summary sheets by combining recommendations where possible. The complete
unedited working papers that document the AD ARC’s working groups’ review, analysis,
and decisions are available for viewing and download from the ARC Web site at
its implementation action, and outcome are excerpted from the FPWG summary sheets

D2.1 AD Compliance Planning
Task
The FAA should provide timely information about new AD requirements,
in advance of compliance dates, to all relevant FAA field offices. Those
offices should then be responsive to any carrier that requests assistance in
the form of progress-towards-compliance audits or reviews, in advance
of the AD compliance dates. The FAA should revise its workload
management systems (including ATOS), so that it can accommodate
such requests.
The IRT believes that this particular form of collaboration should benefit
the air carriers and the FAA, while protecting the traveling public by
reducing the chances of major disruptions.
(IRT report, recommendation No. 2)
In collaboration with the FAA and the ATA, a policy needs to be established regarding
AD compliance. Also, identify the elements of an effective AD compliance process that
exist in air carrier manuals and FAA guidance.
Based on the IRT’s recommendation No. 2, the FPWG analyzed existing documents and
determined that the elements of AD management are poorly defined. The FPWG
determined to develop policy and guidance outlining the basic elements of an effective
AD management process. An air carrier could then create its own AD management
program based on these basic elements.
The six basic elements of an AD management process should consist of—

(1) Planning: Review applicable documentation needed to implement an AD.
(2) Support: Analyze and determine what logistical and personnel support is needed
to implement an AD.
(3) Provisioning: Ensure that the materials specified in the AD and/or AMOC are
available at the scheduled time for AD accomplishment.
(4) Implementing: Finalize and execute the actions involved in the Planning,
Support, and Provisioning elements.
(5) Recording: Record and archive documentation used in the
AD management process.
(6) Auditing: Provide a comprehensive method to continually verify and validate AD
compliance.

Implementation
The FPWG determined that progress toward compliance identified by the IRT would be
best resolved by coordinating with the AIWG to develop a new AC. The AIWG provided
the elements of an AD process and expanded on an air carrier’s specific process, which
were incorporated in the appendixes of the AC. This collaboration ensured the links to
both AIWG and FPWG recommendations were addressed. AIWG and FPWG
implementation proposals will establish the policy, guidance, and procedures to use in the
AD management process. In addition, the FAA’s policy on effective AD management
will made publically available through an AC on AD management.
Based on the IRT’s recommendation, the FPWG developed the following policy and
guidance regarding the AD management process:
(1) FAA Order 8900.1, a new chapter titled AD Management Process.
(2) AC 39–9, Airworthiness Directives Management Process, published on
June 1, 2011
(3) NOTE: Both the new chapter for FAA Order 8900.1 and AC 39–9 address
the six elements of an AD management process listed in Review of
Issue/Problem above.
(4) AC 120–79A, Developing and Implementing an Air Carrier Continuing Analysis and
Surveillance System: Revision for the AD management process.
(5) AC 120–16E, Air Carrier Maintenance Programs: Revision for the
AD management process.
(6) NOTE: Updates for AC 120–79A and AC 120–16E were secondary actions
contingent upon the publication of AC 39–9 and were not scheduled to meet the
June 30, 2011, deadline.
AFS National Field Office for Air Transportation Oversight System (ATOS), AFS–900,
incorporated the new AD management process into the items below.
 Air Transportation Oversight System, Data Collection Tools 1.3.6, Airworthiness
Directive Management.
The FAA revised the two training courses identified below to address AD ARC
recommendations and are expected to be completed by July 2011:
 Training Course 25704, Foundation for Principal Inspectors.
 Department of Transportation’s eLMS for AD Training Course No. 2710009.
Outcome
The FPWG’s implementation action successfully addresses the IRT’s recommendation on
operator assistance with progress toward compliance before AD compliance due dates
with the issuance of new AC 39–9; a new chapter in FAA Order 8900.1, on the
AD Management Process; new and updated training courses; updated DCTs; and
revisions to AD management process in AC 120–79A and AC 120–16E.

In addition, the FPWG noted the IRT assumed that the FAA does not provide timely
information regarding ADs. However, the FPWG believes this is an incorrect assumption
because ADs are posted in the Federal Register as an NPRM and as a final rule. The
documents are readily available from the Federal Register and from the
Regulatory Guidance Library via the following links:
 http://www.gpo.gov/fdsys/browse/collection.action?collectionCode=FR
 http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgAD.nsf/Framese
t?OpenPage
Both Web sites provide a notification service, which will generate an email notification.
Any individual may receive notification by make and model regarding an aircraft engine
or product.
D2.2 AEG Roles and Responsibilities

Task
Primary
Strengthen the role of the AEG in developing and implementing ADs.
Ensure ASIs know that the AEG is a resource for reviewing the
air carrier’s AD installation instructions and that the AEG acts as the
liaison between the CMOs and the ACO on AD implementation issues.
When questions arise, make the AEG part of these processes to make
compliance with the AD as seamless as possible. This approach will help
to prevent future disagreements between the FAA and the air carrier.
Secondary
Recommendation No. 1—Compliance Versus Noncompliance
Decisionmaking Process
The FAA should review the AMOC process for enhancements and to
ensure AEG personnel are included in the process.

 The FAA should establish a formal notification and coordination policy on
how to handle issues where compliance is unclear. The policy should
clearly delineate the AEG’s role in assisting with noncompliance
determinations, specify who has decision authority, and provide guidelines
for elevating issues of disagreement for resolution (see recommendation
No. 8 below). Such a policy will enhance overall coordination efforts and
help the AEG to better coordinate with the ACO.

 The FAA should consider an organizational and procedural change to
ensure FAA field offices have a direct link to the AEG. This will help the
CMOs obtain technical advice on ADs and all issues concerning certificate
management.
(AD CRT task 2 report, recommendation No. 7, bullets No. 1 and 2)
Under all circumstances, FAA technical personnel must be consistent in

reviewing, approving, and applying the processes under their
responsibility. If there are concerns regarding outside undue influence,
the affected party must seek guidance from organizations having the
appropriate level of ability and authority to provide the guidance required
to address the concerns. FAA policymakers must ensure individuals
responsible for the control of the AMOC processes are fully aware of the
scope of their responsibilities. They should also be aware of the available
recourse for appropriate management guidance where required.
Educating these individuals will help ensure proper and prompt technical
resolution of problems. Specifically, the Team recommends the
following:
 The FAA, in coordination with industry, should charter a working group to
review and develop a means to strengthen the AMOC process. The
group’s charter should include a review of the following:
o Communication channels.
o Simultaneous coordination of an AMOC with the ACO and the CMO.
o Concurrence (that is, ACO expeditiously receives concurrence from
AEG on the AMOC, and AEG advises CMO).
o Staff availability on a 24/7 basis (ACO, AEG, and CMO).
(AD CRT task 2 report, recommendation No. 8, bullet No. 1, sub-bullet

Nos. 1, 2, 3, and 6)
The FAA should provide timely information about new AD requirements,

in advance of compliance dates, to all relevant FAA field offices. Those
offices should then be responsive to any carrier that requests assistance in
the form of progress-towards-compliance audits or reviews, in advance
of the AD compliance dates.
(IRT report, recommendation 4.2)

The AEG is the AFS organization responsible for determining the operational suitability
of newly certificated and modified aircraft. The AEG plays a critical role in pilot
qualifications, flight crew training, minimum equipment lists, acceptance and approval of
ICAs for all aircraft, engine and propeller certifications, and other continuing
airworthiness requirements. The AEG is instrumental in—
 Reviewing and determining the operational suitability of ADs by providing
consultation and
 Assisting AIR project managers who develop ADs.
The focus area is on the AEG’s active participation in the AD process. The ACO
determines if the AEG participates during the development of the subject AD. The AEG
provides technical expertise to the ASIs when needed for ADs through technical
consultation to CHDOs and CMOs. The AEG also serves as liaison with ACOs, DAHs,
CMOs, and CHDOs to distribute and answer questions on service instructions and
maintenance alerts.
Although one of the AEG functions is to support the CMO on ADs, ASIs apparently did
not recognize the AEG as a resource when AD compliance is in question. The FPWG
created the ASI decision tool to emphasize the AEG’s involvement in compliance
determinations. In addition to communication with the ACO, the AEG should act as a
liaison between the ACO, ECO, and CMO on implementing ADs. The FPWG agreed
with the AD CRT that emphasis on the roles and responsibilities of the AEG needs to be
added in policy and guidance.
The FPWG noted it agreed with all the AD CRT recommendations with the exception of
an AEG organizational change. In considering the AD CRT recommendation for an
organizational and procedural change, the FPWG reviewed an internal FAA report on
the AEG, as well as the AD CRT task 2 report, recommendation No. 7, and disagree that
an organization change is needed. The FPWG believed the following items will address
the areas where communication failed:
 Clarify existing procedures in guidance.
 Create new guidance.
 Develop new training regarding AEG roles and responsibilities.
The policy/guidance and training proposed by FPWG clearly delineates the AEG’s earlier
involvement and assigned responsibility as a liaison and technical expertise to support
operational suitability, evaluation, certification, implementation, and continued operation
and maintenance of the aircraft. This guidance will also assist the PI and CHDO with
noncompliance determinations as well as provide guidelines for elevating issues of
resolution disagreements to upper FAA management.

The FPWG further determined that an outreach process is needed to facilitate AEG
communication with ASIs in the field regarding complex aircraft/fleet issues to include
ADs. The AEG’s role is essential for communication and collaboration among the ASI,
ACO, and certificate holders in crises involving compliance issues.
In analyzing the AD CRT’s secondary recommendations, the FPWG determined there

were three major issues:
 Collaboration among key stakeholders,
 Communication among key stakeholders, and
 A standard AMOC process that FAA personnel could follow and one that would
allow ASIs to consider their professional judgment when determining
AD compliance.
After analyzing each issue, the FPWG determined new guidance would be needed in
FAA Order 8900.1 that would identify the roles and responsibilities of the AEG as well as
promote communication among AEG, ACO, and ASIs.
The FPWG also determined that additional guidance should be developed to address the
processes regarding AD development, AMOC proposals, and 24/7 support requests. In
addition, the guidance would also identify actions needed to promote collaboration,
which would allow escalation of concerns.
Finally, to fully address the secondary recommendations, the FPWG determined that
additional work instructions, formal training courses, and outreach would be needed to
communicate to the FAA community the proposals outlined in this section.
However, in analyzing possible reorganization to promote improved communication, the

FPWG determined the current organizational structure was adequate and deemed a
staffing increase more appropriate. The FPWG’s analysis of this issue included a review
of the new ASI decisionmaking tool, which emphasizes the communication of FAA field
offices with the AEG. (This tool is discussed in section D2.3 of this report.)
Implementation
To implement its proposals, the FPWG—
(1) Added a new section in FAA Order 8900.1 (vol. 3, ch. 59, sec. 2) incorporating
AIR–ANM–029–W1, Transport Airplane Alternative Method of Compliance
(AMOC) Letters, on how to process AMOC requests. This section refers to
AIR–ANM–029–W1 and Order 8110.103A, which defines AMOCs to ADs. This
guidance contains triggers that involve the AEGs, thus ensuring continued
operational safety of an aircraft at the appropriate time.
(2) Added a new section in FAA Order 8900.1 (vol. 3, ch. 59, sec. 4) incorporating
AIR–ANM–029–W2, Transport Airplane 24/7 Flight Standards AMOC Request
Support Process, on how to process 24/7 support requests. Created a new section
in FAA Order 8900.1 (vol. 3, ch. 59, sec. 3) that defines the 24/7 AMOC process,

which could help prevent the grounding of 10 or more aircraft. This guidance
would contain triggers for AEG’s involvement based on FAA Order 8110.103A,
Alternative Methods of Compliance (AMOC) and requirements.
(3) Added a new chapter in FAA Order 8900.1, titled AEG Roles and
Responsibilities, detailing AEG roles and responsibilities.
(4) Added a new chapter in FAA Order 8900.1, titled AEG Outreach, incorporating
AEG outreach for ADs.
(5) Developed a new training course addressing AEG roles and responsibilities and
their interfaces with the ACO, which included a Web-based and a formal
academy course. The training program defines the communication protocol and
elaborates on the responsibilities and positions of each group (for example,
AEGs, ASEs, and ASIs).
(6) Developed new Web-based training course addressing the AMOC 24/7 process.
(7) Created a memo from AFS–1 that addresses the role of the AEG and directs
reconnecting AEG’s involvement regarding ADs. The memo ensured FAA
field personnel understand that the AEG is a key resource for technical issues
and continued operational safety and established lines of communication.
AFS–1 issued the memo on March 29, 2009.
(8) Created a memo from AFS–1 addressing AEG staffing to support an increase.
This memo was approved on March 3, 2010, and staffing has been increased.
(9) Briefed to the field the AMOC 24/7 Implementation Memo. The 24/7 process
was implemented January 27, 2010, and field briefings were completed
June 2010.
(10) Revised the AD Manual to incorporate AEG coordination specifically to include
an AEG specialist’s involvement earlier in the AD development process. The
early involvement will help AEG determine when to activate an outreach
program to a PI if appropriate.
(11) Conducted FAA field briefings on the AMOC 24/7 process. This was
completed in June 2010.
(12) Submitted a draft update to FS 1100.1B, AFS Organizational Handbook for
AFS–100 that clarifies AEG’s position within AFS and its roles and
responsibilities.
(13) Submitted a request for revision to FAA Order 1100.5C, which is outdated both
for AFS and AIR, to be updated to match FS 1100.1B.
(14) Created a new chapter in FAA Order 8900.1, (vol. 3), titled
ASI Decision Making.
Outcome
The FPWG’s implementation actions successfully address the AD CRT’s primary and
secondary recommendations related to AEG roles and responsibilities during the
AD process. The implementation actions regarding the AEG also address the

IRT’s recommendation noted above. Notably, the FAA revised Order 8900.1 to include
the final guidance on AEG roles and responsibilities, AEG outreach efforts for ADs,
how to process AMOC requests and 24/7 urgent AMOC requests to include
AEG involvement, and ASI decisionmaking. The FAA also revised the AD Manual
to incorporate AEG coordination in the AD development process.
The FPWG considered an organizational change as recommended by the AD CRT and

determined that such a change is unnecessary. Instead, the FAA made the aforementioned
guidance, communication, coordination, and process changes and increased
AEG staffing levels.
D2.3 ASI Decisionmaking

Task
Primary Recommendation
The Team found that during the events precipitating this review, FAA
administration of the AMOC process was reported to be inconsistent and
sound technical judgment did not always govern decisions.
 ―The Independent Review Team made a recommendation that inspectors
should not be required or expected to conduct any type of risk-assessment
before taking action on AD noncompliance.‖ The Team agreed with this
finding as supporting the necessary enforcement needed once an airplane
has been determined to be noncompliant. However, the Team developed a
supplemental process to help the ASI first coordinate a valid determination
of compliance in cases where the condition is not obvious. The Team
recommends that the FAA:
o Develop further guidance and training to assist FAA staff in correctly
determining noncompliance.
o Develop a formal policy regarding ASI decision-making. The policy
should emphasize the technical authority of the ACO and the FAA’s
position on the authority of ASIs to use professional judgment when
determining compliance. To eliminate single-person determinations,
the policy should address any conflicts that arise on an AD or AMOC
by requiring the CMO to elevate its concerns first to the AEG for
resolution. The team addressed the concern of using professional
judgment and avoiding single person determinations in the
ASI Decision making procedures.

 The FAA should develop a decision-making flowchart as a guide for ASIs
making compliance determinations. The following ASI decision flowchart
is provided to demonstrate the notion the Team wishes to convey. (See
Appendix C of the AD CRT Task 2 Report for the flowchart.)

Secondary Recommendation
Based on the findings in appendix A of this report, the Team developed
the following recommendations, which it categorized by process areas.
Because a number of the recommendations cover multiple findings, the
Team is presenting its findings separately. See appendix D for a
cross-reference of the recommendations to the specific findings in this
report. The Team will investigate a number of the recommendations
during task 2.
Recommendation No. 1—Compliance Versus Noncompliance

Decisionmaking Process
The FAA should—
 Develop a more objective, deliberative decisionmaking process for
determining compliance versus noncompliance that can be used in
any situation.
 Reemphasize to ASIs that they have the authority to use professional
judgment to determine whether noncompliance exists.
 Develop a decision tool for use by ASIs to assist in using professional
judgment when making compliance determinations.
 Streamline and improve the process for making compliance
determinations and make it impervious to external influence.
 Eliminate single-person decisionmaking.
 Clarify the roles and responsibilities of the AFS, AIR, OEM, and air
carrier in the compliance decisionmaking process.
 Develop a process to raise ASI concerns on compliance determinations to
a higher level.
 Define and strengthen the communication process flow and make it
impervious to external influence.
(AD CRT task 1 report, recommendation No. 1, bullets Nos. 1–6, 8,

and 9)
The FAA should retain the right to ground any plane not in compliance
with an applicable AD. Inspectors should not be required or expected to
conduct any type of risk-assessment before taking action on
AD noncompliance.
(IRT report, recommendation 4.1)

Primary Recommendation
Without being required to conduct a risk assessment, FAA ASIs should rely on
professional judgment as well as available resources to help determine AD compliance.
The resources should include new policy, guidance, training, and a decisionmaking
flowchart. The new decisionmaking policy should emphasize the authority and role of
key stakeholders, such as ACOs, ASIs, CMOs, and DAHs.
The FPWG reviewed how ASIs could coordinate internally within the FAA and
externally with operators to determine and/or validate AD compliance. Based on its
analysis, the FPWG proposes to develop policies within FAA Order 8900.1 that would—
 Guide the ASI during the decisionmaking process regarding AD compliance.
 Include a decisionmaking logic flowchart, which shows that ASIs have the
authority to determine if noncompliance exists. By following the flowchart, ASIs’
decisionmaking logic would be guided by their work with regional personnel in
the AEG and ACOs when determining AD compliance.
 Outline how an ASI should review an AMOC proposal to an AD.
Secondary Recommendation
The FAA should develop a standard process that helps an ASI determine, regardless of
the situation, whether or not an aircraft complies with an AD. The standard process
should address the following concerns:
 The role of the ASI: How can ASIs objectively determine an aircraft’s
compliance to an AD while still using their professional judgment, as defined in
FAA Order 8900.1, (vol. 1, ch. 3, sec. 2).
 Collaboration: How do ASIs and other groups (such as ACOs, AEG, and
operators) interact with each other to promote transparency, communication, and
collaboration? How can a single person be prevented from determining
AD noncompliance?
 Standardized Resources: What resources (that is, training, guidance, and tools)
are available to help ASIs determine AD compliance?
The FPWG noted these new policies and procedures for the FAA community will take
time for personnel to embrace, accept, and act upon. Also, the ACO and AEG workload
is expected to increase because of the introduction of new guidance.

In addition, the FPWG noted the AD CRT recommended that training be developed to
assist the ASIs in correctly determining noncompliance. This recommendation was based
on the assumption that there was a lack of policy and guidance for ASIs in determining
AD noncompliance. The FPWG evaluated and determined current training is adequate.
Specifically, the foundation for PI’s Training Course No. 25704, which is open to all
ASIs, provides adequate training in determining compliance. The FPWG determined that
this course should be mandatory for all part 121/135 airworthiness ASIs with operators
having 10 or more aircraft, which should be completed by the end of FY 2012.
Implementation
The FPWG created new policy that provides standardized guidance to ASIs when
determining if an aircraft complies with an AD and how that determination may apply to
other aircraft in a fleet. The new policy outlines the processes to solve difficult issues
and eliminate single-person determinations.
The FPWG implemented the following actions to address the AD CRT’s primary and
secondary recommendations:
(1) Mandated all part 121/135 airworthiness ASIs with operators having 10 or more
aircraft complete Training Course No. 25704, Foundation for Principal Inspectors
which addresses ASI decision making and the RMP.
(2) Created new guidance in FAA Order 8900.1, as discussed in this section. The
guidance consists of the following:
a. FAA Order 8900.1, (vol. 3), A new chapter 60 titled ASI Decision Making
that—
 Provides guidance to ASIs for addressing situations in which the
compliance of an aircraft is in question.
 Provides guidance on how and when to determine coordination with AEG
and ACO.
 Includes a logic flowchart that provides systematic procedures that can be
followed to eliminate single-person determination and to elevate concerns
regarding AD compliance.
 Re-emphasizes the RMP that provides ASIs with procedures on how to
manage hazards and their associate risks
(see FAA Order 8900.1, (vol. 10, ch. 3)).

b. FAA Order 8900.1, (vol. 3). A new section provides guidance to ASIs
regarding their role in the AMOC process.
(3) Based on the above changes, AFS–900 revised the following ATOS DCTs to
correlate with FAA Order 8900.1:
 DCT Element 1.3.1, Maintenance Program;
 DCT Element 1.3.3, Maintenance Facility/Main Maintenance Base;

 DCT Element 1.3.4, Required Inspection Items;
 DCT Element 1.3.6, Airworthiness Directive Management; and
 DCT Element 2.1.1. Manual Currency.
Outcome
The FPWG’s implementation actions successfully address the AD CRT’s primary and
secondary recommendations related to ASI decisionmaking by creating standardized
guidance to coordinate difficult AD compliance decisions with all stakeholders and
eliminate single person decisionmaking and to assist with processing AMOCs. The
implementation actions also address the IRT’s recommendation by providing ASIs with
procedures on how to manage hazards and their associate risks.
D2.4 Delegation
Task
 Further delegation to designated engineering representatives (DER) and
authorized representatives (AR), to include AMOCs that address issues in the
systems and equipment, payloads, and airplane performance areas.
 Delegation of AMOCs to other ACOs.
(AD CRT task 2 report, recommendation No. 8, bullet No. 1,

sub-bullets 4 and 5)
The FPWG noted a chartered team within the FAA thoroughly studied further delegation
to DERs and ARs before the AD ARC was formed. This FAA internal team’s final report
recommendation is that, while there is some theoretical opportunity for further delegation
to DERs/ARs for systems and equipment, payloads, and airplane performance AMOCs,
the data51 indicate there were few projects where expanded delegation could have been
applied during the FAA internal team’s 6-month study. At the same time, the
FAA internal team identified certain types of structural AMOCs that can be delegated.
The FPWG Delegation Subteam reviewed the FAA internal team’s report and, based
largely on the information it conveys, agreed to the following:
Expand AMOC delegation to allow two additional types of structural single-airplane

AMOCs to DAH designees:
 The approval of an alternate inspection method, thresholds, or intervals where a
new repair or modification results in the inability to accomplish the existing
AD-mandated inspection or necessitates a change in the existing AD-inspection
threshold. The standard for these approvals is § 25.571, amendment 45 or later.
51
Data studied represented transport airplanes and air carriers that use these products due to the focus of the
AD ARC activity. However, all policy changes which expand delegation will be applicable to other
products as well and not limited to transport airplanes. Additionally any US TC holder/ODA could be
granted AMOC approval authority.

 The approval of AMOC structural deviations to structural designees for ADs
issued by any ACO branch (including Cabin Safety and Systems and Propulsion),
using the existing structural delegation limitations. To do this, future ADs could
utilize a delegation statement identical to those statements in many structural ADs
that is, AD 2010–05–04, paragraph (h)(3). Two examples of this would be
deviations to a structural repair to a thrust reverser AD issued by the Propulsion
Branch or structural deviation that occur during a modification required by an
AD issued by the Cabin Safety Branch.
The FPWG Delegation Subteam studied the delegation of AMOCs to other ACOs within
the context of the AD ARC activity. The Delegation Subteam carefully balanced the need
for further delegation of AMOCs as compared to the need for consistency and
standardization of results. Currently, the subteam does not recommend delegation of
AMOCs from issuing ACOs to other ACOs. The subteam found delegation of AMOCs to
other ACOs is not an effective or efficient AMOC delegation strategy because other
ACOs do not have the data or analysis related to the continued operational safety issue or
the working familiarity with the airplane design. Further, such delegation is counter to
the need for a standardized approach for issuing AMOCs for a given AD.
The FPWG also explored the possibility of delegating global AMOCs and determined
that there may be procedures by which global AMOCs can be responsibly delegated.
Implementation
In many cases, the Delegation Subteam discovered that, while not explicitly addressed in
existing guidance, the delegation of structural single-airplane AMOCs to DAH designees
already occurs on a case-by-case basis. The Delegation Subteam considers that the
update and distribution of the following FAA Orders provide sufficient guidance to
facilitate widespread use of such delegation:
 FAA Order 8100.15, Organization Designation Authorization Procedures,
 FAA Order 8110.37D, Designated Engineering Representative (DER)
Handbook, and
 FAA Order 8110.103, Alternative Methods of Compliance.
The FPWG proposed to develop processes to expand the delegation of approval of global
AMOCs in the following areas:
 Correcting typographical errors in SBs to the issuing organizational designation
authorization holder; and
 For the two additional types of structural single-airplane AMOCs
discussed above.

Outcome
The FPWG’s implementation action successfully addresses the AD CRT recommendation
through the FAA update and distribution of guidance to facilitate widespread delegation
of structural single-airplane AMOCs to DAH designees in Order 8100.15A,
Order 8110.37E, and Order 8110.103A CHG 1.
The FPWG agreed with the FAA internal team finding that expanded delegation for
AMOCs for systems and equipment, payloads, and airplane performance areas is
unnecessary at this time because of its limited value. In addition, the FPWG found that
AMOC delegation to other ACOs is ineffective and inefficient because other ACOs do not
have the required data or analysis or are unfamiliar with the airplane design. In addition,
AMOC delegation to other ACOs would create inconsistencies among AMOCs issued for
a given AD.
Order 8100.15A, Order 8110.37E, and Order 8110.103A CHG 1 include expanded
delegation authority for certain global AMOCs to DAH designees.
D2.5 Part 39
Task
The FAA should review §§ 39.7 and 39.9, and, if necessary, revise those
sections to clarify that AD compliance is an action required of the
operator; it is not necessarily determined by a strict comparison of the
aircraft to AD-specified configurations.
Section 39.7 states ―[a]nyone who operates a product that does not meet the
requirements of an applicable airworthiness directive is in violation of this section.‖
This language mandates both action by the operator and continued compliance with the
AD requirements (for example, ―configuration‖).
Section 39.9 does not impose requirements; rather, it is an explanatory section that
emphasizes the impact of noncompliance. It was added to the final rule because of
comments that the proposed version combined compliance and noncompliance issues
in one heading (proposed § 39.5, final version is § 39.7). The final rule stated that the
agency added § 39.9 ―to refer to § 39.7, which is the rule that operators will violate if
they fail to operate or use a product without complying with an AD that applies to
that product.‖
The FPWG noted the AD CRT recommendation seems to be based on the change of
words in the regulations to accommodate the FAA’s directive to write rules using ―plain
language‖. These changes unfortunately, have created more confusion rather than
making the regulations more clear.

However, the FAA has the authority to provide reasonable interpretations of its rules. In
this case, the FAA indicated in the NPRM and specifically stated in the Final Rule that
the rewording of part 39 did not introduce any new regulatory requirement. There was no
change in the FAA’s legal authority or general interpretation that once an AD is applied to
a product, it must be operated in conformity to that AD on every flight.
The recommendation may also have been precipitated by instances where the operator
believed it was in compliance with an AD, but were subjected to extreme scrutiny with
respect to minor deviations from the specific instructions in the service instructions
incorporated by reference in the AD.
Rewriting of Part 39 in Plain Language

FPWG members expressed opinions regarding the verb usage and tense in the current
plain language version of part 39. The sections that are particularly troublesome are
presented below, with the ―old‖ version (where applicable) in italics.
(1) Section 39.11. What actions do airworthiness directives require?

Airworthiness directives specify inspections you must carry out,
conditions and limitations you must comply with, and any actions you
must take to resolve an unsafe condition.
Section 39.11 Applicability. This subpart identifies those products in

which the Administrator has found an unsafe condition as described in
Sec. 39.1 and, as appropriate, prescribes inspections and the
conditions and limitations, if any, under which those products may
continue to be operated.
The opinion was expressed that a reasonable interpretation of the language directing
action to ―resolve an unsafe condition‖, limited the FAA from requiring actions that did
not relate to correcting the identified unsafe condition. In other words, that an AD is
limited to those tasks that resolve the unsafe condition, whether the tasks are explicitly
listed in the AD or part of a referenced SB.
The opinion was expressed that this section is merely descriptive of the types of actions
required by ADs; it neither imposes obligations on the operator nor limits the FAA’s
authority in issuing ADs.
(2) Section 39.9. What if I operate an aircraft or use a product that does
not meet the requirements of an airworthiness directive? If the
requirements of an airworthiness directive have not been met, you violate
§ 39.7 each time you operate the aircraft or use the product.
The FPWG held extensive discussions around the use of plain language.
The minority position was that the use of the words ―have not been met‖ indicated that
―if‖ the unsafe condition was indeed fixed at a moment in time, this section of the
regulations did not apply. In other words, if the AD was at one time complied with as

required by § 39.11, this section could not be applicable. The conclusion of the position
was this regulation pointed to a specific moment in time, that is, once the unsafe
condition was corrected, the regulation no longer applied, even if the product was later
determined to be contrary to the requirements of the AD. If the product was operated
―out of configuration‖, § 43.13(b) would be violated, not section § 39.7.
The opposing majority position is that language of § 39.7 (as well as its earlier version,
§ 39.3) imposes an operational mandate that the requirements of the AD be maintained
for each operation occurring after the actions required by the AD are accomplished. It
was pointed out that this legal effect was recognized by the AD CRT in its finding and
recommendation No. 11. Section 39.7 stresses that for continuing operations of products
that do not comply with ADs, each flight is a separate violation. The emphasis on verb
tense is misplaced; if a product once complied, but for whatever reason no longer
complies, the requirements of the AD ―have not been met‖ when the product is operated.
(3) Section 39.7. What is the legal effect of failing to comply with an
airworthiness directive? Anyone who operates a product that does not
meet the requirements of an applicable airworthiness directive is in
violation of this section.
Section 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.
The FPWG concluded the language in both the old and new version indicates that the
product must comply with the AD whenever it is operated or a violation will result.
Difficulty of Determining Compliance

FPWG members representing industry expressed frustration over the extraordinary
scrutiny regarding ―compliance‖ with material in service instructions (incorporated by
reference in ADs) that did not have direct relevance to correcting the unsafe condition.
Examples ranged from typographical errors to providing incorrect methods for obtaining
access to an area that needed inspection. It was noted that operators’ deviations from
referenced service instructions have resulted in failure to correct the unsafe condition(s).
The determination of whether a particular action described in the referenced service
information is required must be based upon the specific action required by the AD.
An opinion was expressed that if the method of compliance contained information that
was not necessary to correct the unsafe condition, the FAA may be promulgating a rule
that is beyond the stated purpose of part 39. While § 39.11 describes the content of ADs,
it does not limit the FAA’s general rulemaking authority, as defined in Title 49 of the
United States Code § 44701. The FPWG urged the FAA to consider the implication of
operators having to obtain AMOCs for such unintended matters, particularly the burden
on the operators, AIR, FAA designees, and the FAA ASIs responsible for oversight.

The FPWG believed that while better written service instructions may eventually solve
the issue of having to obtain an AMOC for typographical and other errors, there is an
immediate need to quickly determine whether the operator can follow the AD’s means of
compliance. If there was an ability to determine that the method contemplated or used
was ―in accordance with‖ the AD’s means of compliance, it might reduce the number of
AMOCs and reduce the fear of finding noncompliance over unintended matters. The
FPWG developed a means of compliance process for FAA consideration.
The FPWG noted that some key issues regarding determining compliance have been
tasked to other working groups, namely, the development of better service information
and ADs as well as processes for compliance planning.
The FPWG also noted the need to understand exactly what is required by the AD versus
the information that is contained in a referenced service document. Often, there is
information contained in a referenced service document that is not required by the AD,
however, in some cases, the industry and the FAA are finding it difficult to distinguish
those items sufficiently.
Design Changes In Production Aircraft Versus In-Service Aircraft

The FPWG discussed the difference in regulatory treatment between an aircraft that has
had design changes incorporated during production and an aircraft that has been modified
in accordance with an AD to incorporate the identical design change.
In the first instance, an air carrier’s maintenance program manages any deviations from
the configuration as well as the continued airworthiness (maintenance) of that change
under § 43.13, while in the latter instance, deviations must be handled through the
AMOC process.
An AD is a rule that is published as a stand-alone requirement that changes the approved

design of aviation products and appliances. For example, if an AD requires the removal
and replacement or alteration of an article, the previous article’s configuration is no
longer eligible for installation, that is, if it were installed, the product or appliance would
no longer meet an approved design. Similarly, if an AD required an inspection at
specified intervals, missing an interval would render the aircraft noncompliant because it
would not be in a condition for safe operation, that is, the inspection is required to
determine that it remains in a safe condition. The AD-required inspection has the same
legal effect as an airworthiness limitation approved as part of the aircraft’s type design.
When an aircraft (or other product) is released from a production approval holder’s
quality system, it must conform to its approved design and be in a condition for safe
operation (see § 21.165(b) and revised § 21.146(c)). This would include any type design
changes whether initiated voluntarily by the DAH or required by the FAA (see §§ 21.95,
21.97, and 21.99).
All maintenance and alteration activities must be accomplished under part 43.
Section 43.13 requires maintenance to be performed in accordance with methods,
techniques, and practices acceptable to the FAA (usually, the maintenance instructions or

ICAs from the design/production approval holder) and the work performed must return
the article (aircraft) to at least its original (or properly altered) condition. Therefore, to
ensure compliance with either the original configuration of the production certificate
holder or an AD mandated configuration, the operator must ensure its maintenance
program is returning the aircraft to at least its original or properly altered (that is an
airworthy) condition.
If the design or configuration of the production aircraft did not include an article
prohibited by an AD (for example, the AD did not apply because the type design was
changed and excluded the prohibited article), the original condition of the aircraft would
not allow the prohibited article’s installation during maintenance activities because it
would not return the article to at least its original condition. Furthermore, the installation
of a prohibited (unsafe) article could not be considered properly altered under part 43
because it would not meet its approved design.
The difficulty with these distinctions may be addressed by enhancing the use of § 21.50
relating to issuing and updating instructions for continued airworthiness. Whenever a
major change to type design is introduced, especially one that is the basis for an AD, the
DAH should ensure that mandatory configuration or inspection action is noted in
revisions to maintenance documents.
Post-Modification Maintenance
There were discussions of whether the product or article could return to the operator’s
maintenance program (that is be maintained or altered under part 43) after a terminating
action was accomplished.
Examples included:
 An AD provides the option of inspection every 1,000 flight hours or replacement
as a terminating action. The operator terminates the inspection requirement by
performing the replacement and returns to the original program of inspection
every 2500 flight hours.
 An initial AD requires an inspection of an aircraft structural element every
2,500 flight hours and if cracking is found the operator must obtain an approved
repair from the DAH; a superseding AD allows replacement as a terminating
action. After the operator replaces the structural element, the inspection interval
goes back to the original 5,000 hours and if abnormalities are found, they are
repaired in accordance with the structural repair manual.
 The AD requires modification of a component to a fuel system, after the
modification is accomplished, the subsequent maintenance and/or alteration
actions are accomplished in accordance with the component maintenance manual
at the intervals, or on condition, specified by the air carrier’s maintenance
program.

The examples were carefully vetted as ―terminating‖ actions, in other words, the
AD language specifically used the word ―terminate‖, ―terminating‖ or ―terminated‖. In
all these cases, the operating community members believed that the aircraft or component
could be maintained normally (under part 43) after the unsafe condition was corrected.
The FAA took varying positions depending upon the AD requirements.
To the operator community, the word ―terminate‖ means end; it is difficult for operators
to understand any other result. If the AD allows (or requires) replacement as a
terminating action, the AD should be complete and no further action under the AD should
ever be required. Other actions may be prohibited, for example, the prohibited
configuration cannot be reintroduced. Unless there are specific follow-on requirements
specified in the terminating action, for example, all repairs to this area must always be
approved by the DAH, then terminating must mean end.
The FAA pointed out that the phrase ―terminating action‖ is used in ADs to refer to
actions that terminate repetitive actions or on-going requirements specified in other
provisions of the AD, such as repetitive inspections or AFM limitations. It does not
terminate the requirement for the operator to comply with § 39.7 by operating the aircraft
in accordance with the AD-mandated configuration. Particularly in cases where the
unsafe condition addressed by the AD is the result of normal maintenance that had
previously been considered acceptable, such as many wiring ADs, a contrary result would
allow reintroduction of the unsafe condition, including deviation from an element of the
mandated configuration, which would be contrary to the intent of the AD and part 39.
The FPWG found there is no need to revise part 39 to deal with this issue.
The FPWG developed recommendations for AD ARC consideration to resolve and/or

avoid any misunderstandings regarding the legal effect of ADs and to address the
industry concerns underlying recommendation No. 12.
 Develop a means to apply the work of the SIWG to existing ADs. The FPWG
believes that once the SIWG identifies the methodology for ensuring service
information clearly distinguishes between those actions that are critical and those
for which operators should be provided flexibility, the same guidance could then
be applied to existing AD-referenced SBs. This approach would be appropriate
for ADs that operators consider overly prescriptive and would be adopted by
mutual agreement of affected operators and DAHs. The affected operators and
DAHs could work to revise troublesome SBs. These revised service instructions
could then be approved as global AMOCs. See section A2.2 of this report for a
discussion of the SIWG’s solution to identify critical steps in new
 Develop a Means of Compliance request form to help determine whether an
AMOC is necessary for obvious typographical errors, missing or extra steps in a
referenced process that make it impossible to complete without filling in or
ignoring the steps, and other limited circumstances where referenced service
information is erroneous.

 Develop the ability to post general descriptions of AMOCs, stating whether each
contains proprietary information but without revealing that information, so that
the public is aware of the existence and can efficiently seek copies of
non-proprietary AMOCs and the FAA can eliminate some duplicative efforts. See
section C2.3 of this report for the AIWG’s discussion of posting certain AMOCs
on DAH Web sites.
 Develop a legal opinion on the meaning of the questionable sections in part 39 so
that the concerns expressed by the AD CRT are in the proper context. The
concerns raised by the AD CRT involved the use of the plain language in the
regulations as well as the perceived inability to place an aircraft back into a
regular maintenance program once an AD was required. The FAA’s position is
that § 39.9 merely explains the legal effect of any operation of a product in
violation of an AD; and § 39.7 is violated when an aircraft is operated ―that does
not meet‖ the requirements of an AD. Some industry representatives have taken
the position that § 39.9 means that, once an action required by the AD has been
taken, part 39 would no longer apply. Rather, any operations taken after the date
that the AD action was accomplished would be subject to scrutiny under part 43
and the operating rules in parts 91, 121, 129, and 135 for failure to operate an
aircraft in an airworthy condition. The FPWG found a formal legal interpretation
from the FAA would resolve these issues. AFS–301 submitted a request to
AGC–200 for a legal opinion on September 1, 2010. See appendix H for a copy
of the request.
 To address the issues discussed under the headings, Design Changes
In-Production Aircraft versus In-Service Aircraft and Maintenance after
Terminating Action (Post-Modification Maintenance), the FAA should ensure that
manufacturers develop and provide ICAs for all design changes mandated by an
AD. It should also ensure that these ICAs are referenced in the service
information describing the design change as acceptable maintenance procedures
so its use does not require AMOC approval. In addition, the FAA should evaluate
whether other methods, techniques, and practices that would normally be
acceptable under an operator’s maintenance program are acceptable for
maintaining the AD-mandated configuration. If so, either the service information
referenced in the AD or the AD itself should explicitly state this so that AMOC
approval is not required. See a discussion of the SIWG and ADWG reviews of
this issue under section A2.8 and section B2.2 of this report, respectively.
The FPWG contemplated requesting a change to part 39. However, after considerable
discussion, the majority voted not to request a rule change. The dissenting working
group member believes a rule change is necessary and the FPWG documented the
dissenting position in Appendix F to the associated summary sheet report. If the
supposition of recommendation No. 12 was not accepted by the committee, that
AD compliance is an action required of the operator, it is not necessarily determined by a
strict comparison of the aircraft to AD-specified configurations.

Implementation
Because the FPWG determined that a rule change is not necessary, it did not develop an
implementation plan. However, to address the underlying concerns that led to the
AD CRT’s recommendation No. 12, the FPWG proposes the following recommendations
be implemented through revisions to relevant FAA orders and ACs—
 FAA Order 8110.103 should clearly indicate when an AMOC is not required. If
an ACO determines that a proposed AMOC is unnecessary, because the request
identifies a method of compliance rather than an alternative method of
compliance, it should deny the AMOC request.
 AC 39–7C should clearly indicate when compliance has been achieved and how
to determine when steps in an SB are mandatory versus those that are
recommendations of how to proceed to the mandatory actions. While the AC
cannot provide detailed guidance for individual ADs, it should discuss the way
ADs reference SBs and describe the ways in which ADs and SBs distinguish
between required actions and guidance material as defined in the
recommendations of the SIWG and ADWG.
 AC 120–16E should clearly indicate how the operator can distinguish between
means of compliance activities, when an AMOC is or is not needed. This
guidance should be consistent with FAA Order 8110.103.
 AC 120–79 should ensure that the information provided on AD compliance is the
same as in the previously listed documents.
 FAA Order 8110.54 should indicate that when a design change has been required
by an AD or is AD related, that the service information must clearly indicate the
prohibited or required post-modification maintenance actions, or at least reference
the AD, so that AMOCs are not required for acceptable actions.
 AD templates and instructions for their use should ensure that means of
compliance are clearly defined so a determination of whether an AMOC is needed
is concise and standardized.
 FAA–IR–M–8040.1—Re-instate the Airworthiness Directive Action Program
Team (ADAPT) and Intra-Directorate Airworthiness Directive Program Team
(IDAPT) procedures defined in FAA–IR–M–8040.1, sec. 9. Section 9 instituted
communication avenues that have not been followed. The communication
channels and exchange of information would allow the ADAPT team to monitor
the AD process on a national basis and thereby fulfill the charter of the ADAPT
and IDAPT procedures. Without all the representatives identified in section 9, the
team is incomplete and contrary to establishing effective communications.
Note: AD CRT recommendations No. 1 and 11 are interrelated to

recommendation No. 12; therefore, any actions taken based upon this recommendation
should be coordinated with the SIWG (recommendation No. 1) and the AIWG
(recommendation No. 11). When the implementation plans for those recommendations
are finalized, then the suggestions made in this section need review.

DAHs and operators may be required to revise their procedures and manuals to
implement the recommendations.
Outcome
The FPWG found success of its suggestions is largely dependent on DAH and operator
implementation of AD CRT recommendation Nos. 1 and 11, respectively (see
section A2.7 and section C2.7 of this report for the working groups’ resolution of those
recommendations). Success also depends on ACO and CMO awareness and oversight of
regulatory requirements for all operators involved in the development and
implementation of ADs.
For design changes in production aircraft versus in-service aircraft, the ADWG and
SIWG evaluated this issue. In addition, the ADWG addressed post modification
maintenance. See sections A2.7, A2.8, and B2.2 of this report.
Regarding the FPWG recommendation that FAA Order 8110.103 should clearly indicate
when an AMOC is not required, the FAA noted the order currently defines typographical
errors to be covered by AMOCs. In addition, an appendix will include two questions in
the question and answer section on errors in service information or an AD. The question
and answers will also advise that AMOCs to address errors or typographical errors should
be issued as global AMOCs. The FAA also plans to identify metrics to capture the
number of AMOCs that address errors/typos in ADs or service information to ensure
quality issues are addressed. See section 3.3.2 of this report.
The FPWG suggested certain revisions to AC 39–7C, AC 120–16E, and AC 120–79. The
FAA noted changes to these documents are secondary deliverables. The FAA plans to
revise these documents as appropriate. See section 3.1.3 of this report.
The FPWG recommended FAA Order 8110.54 indicate that when a design change has
been required by an AD or is AD related, that the service information must clearly
indicate the prohibited or required post-modification maintenance actions, at least
referencing the AD, so that AMOCs are not required for acceptable actions. However,
because the SIWG could not resolve the post modification maintenance issue, the order
does not require revision at this time. See section A2.7, A2.8, and B2.2 of this report.
Regarding the FPWG recommendation that AD templates and instructions for their use
should ensure that means of compliance are clearly defined so that a determination of
whether an AMOC is needed can be concise and standardized, the FAA determined that it
will explain critical tasks required for compliance and their effect in each AD, such as the
need for an AMOC. The FAA does not plan to change the AD template but may update
other internal guidance material.
The FPWG recommended the FAA re-instate ADAPT and IDAPT procedures defined in
section 9 of the FAA AD Manual. The FAA assessed the ADAPT/IDAPT charter and
determined that those objectives are met through the standardization management team
therefore ADAPT and IDAPT procedures will not be reinstated.

D3.0 CONCLUSION
The FPWG implemented the majority of the recommendations assigned by the AD ARC
and explained its decision when it did not implement a recommendation or only partially
implemented a recommendation. The implementation actions discussed above support
the FAA and aviation industry decisionmaking process for determining AD compliance.
The improvements for determining AD compliance are as follows:
 Developed policy and guidance regarding the AD management process in
FAA Order 8900.1, a new chapter titled AD Management Process and
AC 39–9, Airworthiness Directives Management Process, published on
June 1, 2011, to include the six elements of an AD management process:
planning, support, provisioning, implementing, recording, auditing.
 Incorporated the new AD management process into (1) FAA training courses
(Training Course 25704, Foundation for Principal Inspectors and DOT’s eLMS
for AD Training Course No. 2710009) and (2) Air Transportation Oversight
System, Data Collection Tools 1.3.6, Airworthiness Directive Management.
 Revised FAA Order 8900.1 to include the final guidance on AEG roles and
responsibilities, AEG outreach efforts for ADs, and how to process AMOC
requests and 24/7 urgent AMOC requests to include AEG involvement.
 Revised the AD Manual to incorporate AEG coordination in the
AD development process.
 Increased AEG staffing to support AD and AMOC process improvements.
 Created new guidance in FAA Order 8900.1 on ASI decisionmaking to include a
logic flowchart to eliminate single-person decisionmaking.
 Developed new guidance in FAA Order 8900.1 on the ASI’s role in the
AMOC process.
 Updated and distributed FAA guidance to facilitate widespread delegation of
structural single airplane AMOCs and certain global AMOCs to DAH designees.
 Expanded delegation of structural single airplane AMOCs and certain global
AMOCs to DAH designees in Order 8100.15A, Order 8110.37E, and
Order 8110.103A CHG 1.

APPENDIX E—AD ARC WORKING GROUP MEMBERS AND
AD ARC PROGRAM SUPPORT STAFF
AD DEVELOPMENT WORKING GROUP

Tim Dowling, Co-lead The Boeing Company (Boeing)
Holly Thorson, Co-lead FAA, TAD, Northwest Mountain Region (ANM)–114
FAA, Seattle Aircraft Certification Office,
Tammy Anderson
ANM–120S
Barry Baker Pinnacle Airlines
Eric Blancaneaux Airbus
Elizabeth Bumann FAA, AIR–113
Tim Dulin FAA, TAD, International Branch, ANM–116
Craig Fabian Aeronautical Repair Station Association
Douglas Gibson Bombardier
Rafael Marques Embraer
Oswaldo de Oliveira Agência Nacional de Aviação Civil
Jim Orchard FAA, AFS, Aircraft Evaluation Group–11
FAA, AFS, Air Carrier Maintenance Branch,
Nick Pearson
AFS–330
Ross Stewart ABX Air
Plamen Stoyanov Alaska Airlines
Invited Subject Matter Experts/Observers
Marco Capaccio European Aviation Safety Agency
AD IMPLEMENTATION WORKING GROUP

Larry Williams, Lead United Airlines (United)
Craig Amadeo Delta Air Lines (Delta)
Herman Bijl Bombardier
Al Boring Alaska Airlines
Elizabeth Bumann FAA, AIR–113 (Alternate for Ken Filippelli)
Eduardo Cerdeira Embraer (Alternate for Carlos Valadares)
Michele Dedic United (Alternate for Larry Williams)
Greg DiLibero FAA
Joe DiPalmo AFS FSDO NY
Craig Fabian Aeronautical Repair Station Association (ARSA)
Ken Filippelli FAA, AIR–112
Rick Hardmeyer American Airlines
Bill Heliker FAA, Seattle (SEA)–AEG
W. Kawehi Lum FAA, Honolulu Flight Standards District Office
Russ Reed AirTran Airways
Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page E–1

Paul Sesny Boeing Company (Boeing)
Adam Troeger American Eagle
Bill Tsai Boeing
Carlos Valadares Embraer
Bill Williams Federal Express (FedEx)
FAA ORGANIZATION/PROCEDURES WORKING GROUP

Steve Douglas, Lead FAA, AFS–301
Doug Anderson FAA, ANM–7
Steve Edgar FAA, TAD
Steve Fox FAA, ANM–120S
Chuck Heald Boeing
Tim Holt FAA, AFS–330
Keith Johnston Learjet
Steve Jones American Airlines
Ken Kerzner FAA, AFS–330
W. Kawehi Lum FAA, Honolulu Flight Standards District Office
Sarah MacLeod Aeronautical Repair Station Association (ARSA)
Tom Newcombe FAA, SEA–AEG
Lynn Pierce FAA, SEA–AEG
Rob Romero FAA, AIR–113
Pete Spofford FAA, AFS–900
Ed Walton United Parcel Service (UPS)
Patty Williams FAA, AFS–330
Support Staff
Paula Martori FAA, AFS–310
Dan Reyes FAA, AFS–310
SERVICE INFORMATION WORKING GROUP

Blaine (Chip) Amidon, Boeing
Working Group Co-Lead
Joe Nolan Alaska Airlines
Working Group Co-Lead
Chris Armes Bombardier Learjet (Learjet)
Elizabeth Bumann FAA, AIR–113
Ed Carter Boeing
Eduardo Cerdeira Embraer
Serge Cheyrouze Airbus SAS (Airbus)
Paul Comeau Southwest Airlines
Gil DaCosta FAA, Aircraft Evaluation Group (AEG)
Craig Fabian Aeronautical Repair Station Association (ARSA)
Mary Fox Boeing

Drew Helder American Eagle Airlines, Inc. (American Eagle)
Ken Hurley Bombardier Aerospace (Bombardier)
Bob McCabe FAA, Northeast Region, Engine/Propeller
Directorate
Maureen Moreland FAA, Aircraft Certification Office
Tom Novello JetBlue Airways
Rose Opland FAA, Transport Directorate
Ron Pekny American Airlines
Jim Phoenix FAA, AFS
Jim Ursitti US Airways
Joe White Air Transport Association (ATA)
Invited Subject Matter Experts/Observers
Marco Capaccio European Aviation Safety Agency
AD ARC PROGRAM SUPPORT STAFF

Dale Johnson Boeing
Dionne Palermo FAA, ANM–105, AFS Liaison Program Manager
John Piccola FAA, ANM–109

APPENDIX F—ACRONYMS
14 CFR Title 14, Code of Federal Regulations
AC advisory circular
ACCP Airworthiness Concern Coordination Process
ACO FAA aircraft certification office
AD airworthiness directive
Aviation Rulemaking Committee for Airworthiness
AD ARC
Directive Implementation
AD CRT Airworthiness Directives Compliance Review Team
ADWG AD Development Working Group
ADAPT Airworthiness Directive Action Program Team
AEG FAA Aircraft Evaluation Group
AFS FAA Flight Standards Service
AGC FAA Office of the Chief Counsel
AIR FAA Aircraft Certification Service
AIWG AD Implementation Working Group
AMM Airplane Maintenance Manual
AMOC alternative method of compliance
AMT aviation maintenance technician
ANM Northwest Mountain Region
AR authorized representative
ARSA Aeronautical Repair Station Association
ASE aviation safety engineer
ASI aviation safety inspector
ATA Air Transport Association of America, Inc.
ATOS FAA Air Transport Oversight System
AVS FAA Office of Aviation Safety
AWL airworthiness limitation
CASS Continuing Analysis and Surveillance System
CHDO certificate-holding district office
CMM Component Maintenance Manual
Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page F–1

CMO certificate management office
CMU certificate management unit
CPF Change Proposal Form
DAH design approval holder
DCT data collection tools
DER designated engineering representative
EAPAS Enhanced Airworthiness Program for Airplane Systems
ECO Engine Certification Office
EIR Enforcement Investigative Report
eLMS electronic Learning Management System
EO engineering order
EPI element performance inspection
EWIS electrical wiring interconnection system
FAA Federal Aviation Administration
FDMS Federal Docket Management System
FPWG FAA Organization/Procedures Working Group
FSDO FAA Flight Standards District Office
IBR incorporation by reference
ICA instructions for continued airworthiness
IDAPT Intra-Directorate Airworthiness Directive Program Team
IFO international field office
IRT Independent Review Team
ISO International Standards Organization
LAACO Los Angeles Aircraft Certification Office
MCAI mandatory continuing airworthiness information
MSAD Monitor Safety/Analyze Data
NAA national aviation authorities
NDT nondestructive testing
NPRM notice of proposed rulemaking
ODA organization designation authorization
OEM original equipment manufacturer

OFR Office of the Federal Register
PAI principal avionics inspector
PI principal inspector
PMI principal maintenance inspector
QMS FAA Quality Management System
RAA Regional Airline Association
RC required for compliance
RMP Risk Management Process
SACO Seattle Aircraft Certification Office
SAI safety attribute inspection
SB service bulletin
SIWG Service Information Working Group
SMS Safety Management System
STC supplemental type certificate
SWPM Standard Wiring Practices Manual
TAD FAA Transport Airplane Directorate
TC type certificate
TCCA Transport Canada Civil Aviation

APPENDIX G—AD ARC CHARTER
u.s. DEPARTMENT OF TRANSPORTATION

FED ERAL AVIATI ON ADMINISTRATION
ARC Charter
Effective Date:
08120/2009
SUBJ: Airworthiness Directive Implementation Aviation Rulcmaking Committee
1. Purpose of this Charier. This charter creates the Aviation RuJernaking Committee (ARC) for
Airworthiness Directive Implementation according to the authority of the Administrator of the Federal
Aviation Administration (FAA) under section I06(P)(S) of Title 49 of the United States Code (49
U.S .c. 106(p)(5» . This charter also olltlines the rommittee'g organiza.tion, responsibilities, and tasks.
2. Audience. TIlls charter ttpplil!S to members of the Airworthiness Directive Implementation ARC,
including members of aviation industry, and employees within the Office of the Associate
Administrator for Aviation Safety: Aircraft Certification Service, flight Standards Service, and
the Office of Rulemaking. The (ludience for this charter also includes employees of the Office of
General Counsel and the Office of Aviation Policy and Plans.
3. Where to Find this Charter. You can find this charter on the FAA website at
http://wv,w.faa.gov/about'committees/rulemaking/.
4. Background. In l!afly March and April 2008, events of suspected noncompliance to airworthiness
directives (AD) prompted US Sccretary of Transportation, Mary E. Peters, to establish an lndependent
Review Team (1RT) to craft recommendations to improve the current aviation safety system. ·I·his
team consisted of five aviation and ~fety experts. Their task was to evaluate and make
recommendations to improve the FAA's implementation of the aviation safety system and its eulture
of safety . The IRT issued their final. report on September 2,2008 . Thcir report identified 13
recommendations related to ADs, Voltmtary Disclosure Prognun, Culrure ofF AA, Safety
Management Sysiems, Air Transportation Oversight System, and the role ofF AA Inspectors.
a An AD Compliance Revicw Team (CRn was also establ ished to review the events that
calL<:ed a major disruption to some airline schedules. TIle team consisted of eight FAA and indu);try
subject matter experts. The team reviewed compliance issues related to AD 2006-15- 15 (Phase 1) and
the general process for developing ADs (phase 2). The AD CRT drafted a report Lo document their
findings and recommendations frum their Phase 1 activity. lbis report noted areas where system
improvc:ments could be made.
b. The AD CRT also drafted a report tu uucwnent their 12 findings and recommendations
from their Phase 2 review, which focused on the process of developing and implementing ADs, and
ensuring compliance. Their findings and reconunendations do not fundamentally change the AD
process, but provide suggested enhancements and improvements. The findings and recommendations
tOcus on the areas of: Service Instructions, Aircraft Evaluation Groups (AEOs), Lead Airline Process
(ATA Specification 111), AD Process and Implementation, Mandatory Continuing Airworthiness
Information, Altemative Methods of Compliance (AMOCs), Crisis Communication, and Part 39
Regulations.
Initiated By AJ\M·100
Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page G–1

0812012009
c. The purpose of this ARC is to evaluate arxI. addrt:~ Lht: recommendations of the AD CRT
and those of the IRT relating to airworthiness directives. Because thcrcoommcndntions of the IRT
and the AD CRTnddress actions to be taken by both the FAA and industry,an ARC is necessary to
ensure that further evaluation and implementation of the recommendations adequ.'\lely considers the
needs and objectives of ill I stakeholde~. Implementation of recommendations may require some
ruiemaldng.
5. Organization and Administration of the Ainvorthiness Diredive Implementation ARC. We

will set up a committee of members of !.he aviation community. including manufacturers and air
carriers, representing diverse viewpoint.;;, FAA participation and support will come from all affected
lines-of-business. Where necessary, the comminee may sel up spei.:iaJiLed work groups that include
inviLed subject matter expelts from industJ.y and the r AA.
a. The committee spolliOr is the Associate Administrator for Aviation So<Itety, who:
(1) Appoints members or organizations to the commiutX, at her sole discretion;

(2) Receives nIl committee recommendations and reports;
(3) Select... industry and FAA co-chairpersons for the committee; and
(4) Provides administJativc support for the committee, through the Aircraft Certification
Serv;ce (AIR) and F!;ght Standards SeMce (AFS).
b. The co-chairpersons will:
(1) Determine (with other committee members) when 3 meeting is required (a quorum is
desiroble at committee meetings, but not required);
(2) ..<\rrange notification 10 all members of the time and pla~ of each meeting;
(3) Draft an agenda for each meeting and conduct the meeting;
(4) Keep meeting minutes; and
(5) Provide status updates to the Associate Administrator for Aviation Safety, at 6 months, 12
months and 18 months from the effective date of this charter.
6. Committee Membership. Ibe committee will consist of about five tu ten members, representing
airplane manufacnrrers, air l:afTiers, FAA, and other aviation industry participants. Membership will
be ba1anced in viewpoints, interests, and knowledge afthe commiuee's objectives and scope.
Committee membership is limited to promote discussion. Active p(lrticipation and commitment by
members is essential tor achieving the committee's objectives. Attendance is essential for oonLillued
membership on the comminee. The committee may iuvite additional participants as subject matter
t:xpcrts to support specialized work groups.
7. Public Participation. Persons or organizations olltside the comminee who want to anend a
meeting must get approval in advance of the meeting from a committee co-chairp..:rson or designated
federal representative.

0612012009
8. Committee Procrtlures and Tasks.
a. The committee advises and provides written recommendations to the Associate Administrator
tor Aviation Safety (AVS-l ).
b. Committee tasks include, but are not limited to, the following:
( I) Establishing work. groups to evaluate and address specific recnmmendations and assigning
IRT and CRT recommendations to each work group.
(2) Developing a program plan and implementation schedule to address the specific
recommendations.
(3) Reviewing. approving, and implementing the program plan.
(4) Monitoring progress and status of work groups and resolving issues raised by those
groups.
(.'i) Advocating the progrnm plan and implementation actions./schedule with tht: respective
stakeholder organizations.
c. The committee may propose additional tasks as necessary to the Associate Administrator for
Aviation Safety for appro\o'al.
d. The ARC will submil a final report detailing recommendations and implementation actions by
24 months from the effective date of this charter. 1be Associate Administrator for Aviation Safety
may extend this deadline for up to 6 montru ifit is in the interest of the FAA to do so.
9. Cost and Compensation. The estimated cost to the Federal Government of the Ainvorthiness
Directive Implementation ARC is $130,000. annually. All travel costs for government employees wilJ
be the responsibility ofthc government employee's orgarrization. Non-government representatives
serve without government compensation and bear all costs oftheir comminee panicipation.
10. Availability of Records. Subject to the wnditions of the freedom oflnfonnation Act, 5 U.S.C.
522, rccorW, reports, agendas. working papers. and other documents made available to, prepared for,
or prepared by the committee will be available for public inspection and copying at the FAA ,
Transport Airplane Directorate, 1601 Lind Avenue SW., Kenton. WA 98057-3356. Fees will be
charged for information furnished to the public according to the fee su1txlule in 49 CFR part 7.
11. Committee Tenn. This committee becomes an entity on the effective date of this charter. The
committee will remain in existence for a term of24 months unless it~ term is ended sooner or
extended by the Administrator.

0812012009
12. Distribution. This charter is distributed to the Ofli(X uf the Associate Administrator for Aviation
Safety, the Office of the Chief Counsel, the Office of Aviation Policy and Plam, and the Office of
RuJemaking.
Administrator

APPENDIX H—PROPOSED FAA LEGAL INTERPRETATION
20090 Federa l Regisler /Vol 76 No 72/ Thursday April 14 20ll/Proposed Rules
Were any other discrepancies notced duling this inspection?

I
For Ercoupe Service Memorandum No. 3S
Did you perform steps 1. 2. and 7 01 the Erl:oup e Service Memo-

randl.m No. 35?
NO
I YES
Were any other discrepancies no~ced during this inspection?
Send report to: Roger A. Caldwel. Aerospace Engineer. FAA. ANM-100D . Denver ACO .
26805 East 68th Avenue. Room 214. Denver. Colorado 80249-6361:
fax: (303) 342-1088; E-mail: roger.caldWefIOfa1J.gov; and
Univair Airl:raft Corporation. 2500 Himalaya Road. Aurora . Colorado 80011
Figure 1
Papenvork Reduction Act Burden Statement St.. Kansas City, 1\10 64106. For information Roo m WlZ-140 of the West Building
(s) A federal agency may not conduct or on the availability of this material at the Ground Floor al 1200 New Jersey
sponsor. and a person is not required to FAA. call (8t6) 329-4148. Avenue, SE.. Washingto n. DC. between
respond to. nor shall a person be subject to Issued in Kansas City, Missouri. on Apri l 9 a.m. and 5 p.m" Monday through
a penalty for failure to comply with a 7.2011. Friday. except Federal holidays.
collection of information subject to the Earl lawre nce. Fa.t. : Fax comments to Docket
requirements of the Paperwork Reduction Monoser. Small Airplone Directorate. Aircraft
Act lUlless that collection of information O perations at 202-493- 2251.
Certification Service.
displays a current valid o~m Control FOR FURTHER tNFORMATlON CONTA CT: John
Number. The OMB Control Number for this [FR Doc. 2011-909t Filed ~-l3-ll: aAS am] King, Staff Attorney. Regulations
information collection is 2120-0056. Public BILUNG CODE 4ilO-13_P Div ision. Office of the Chief Counsel.
reporting for this collection of infonnation Is Federal Aviation Administration. 800
estimated to he approxinlately 5 minntes per
Independence Avenue. SW ..
response. indudin! the time for reviewing DEPARTMENT OF TRANSPORTATION
instructlons. comp eting and reviewing the Washington. DC 20591; telephone: 202-
collection of information. All responses to 267-3073.
this collection of information are mandatory. SUPPLEMENTARY INFORMATION:
Comments concerning the accnracy of this
burden and snggestions for reducing the 14 CFR Part 39 The Ref/uest
burden should be directed to the FAA at: 800 [Docket No. FAA-201o-1167j The Federal Aviatio n
Independence Ave .. SW .. Washington. DC
20591. Attn: Information Collection Administration's [FAA) O rganization/
Proposed Airworthiness Directive
Clearance Officer. AES-200. Procedures Working Gro up (WG) o f the
Legal Interpretation
Airworthiness Directive Implementation
Alternative Methods ofCempliance AGENCY: Federal J\viatio n Aviation Rulemaking Committee (AD
[AMOCs}
Administration. DOT. ARC) requested that the F At\ provide a
(h)[1) The Manager. Denver ACO, FA.J.,.. has legal interpretation of several provisions
the authority to approve AMOCs for this AD, ACTION: Proposed airworthiness
directive interpretation. in 14 Code of Federal Regulat ions (CFR)
if requested using the procedures found in 14
CFR 39.19. In accordance with 14 CFR 39.19. that would help resolve a number of
send your request to your principal inspector SUMMARY: The Federal Aviation issues that have been debated within the
or local flight Standards District Office. as Administration is c onSidering issuing a WG. These issues partly result from
appropriate. If sending infonnation directly legal interpretation on various certain changes made in the plain
to the manager of the ACO. send it to the provisions in the regulations applicable langnage revision to CFR part 31:1 in 2002
attention of the person identified in the to airworthiness directives. Comments (see 67 F R 48003 . July 22. 2002).
Related Information section of this AD from the public are requested to assist
(2) Before using any approved AMOC. the agency in developing the final legal Question l ----Continuing Obligation
notify your Principal Maintenance Inspector interpretation .
or Principal Avionics [Ilspector . as Some members ofthe WG question
appropriate. or lacking a principal inspector. DATES: Comments must be rece ived on the extent of an aircraft operator's
your local Flight Standards District Office. or before May 16. 2011 . continuing obligation to maintain an
(3) AMOCs approved for AD 52--02--02 are ADDRESSES: You may send comments AD-mandated configuration. They ask
approved as AMOCs for this AD. identified by Docket Number FAA- about two regulations:
Related Information 2010- 1167 using any of the following Settion 39.7 What is the l e~~ l effect of
[i) For more information about this AD. metho ds: failing to comply with an airworthiness
contact Roger Caldwell . Aerospace Engineer. Federal eRulemaking POI1al; Go to directive?
FAA. Denver ACO. 26805 East 68th Ave., http://www.regulations.govand follow Anyone who operates a product that does
Room 214, Denver, Colorado 80219-6361: the online instructions for sending your not meet the requirements of an applicable
telephone: (303) 342- 1086: fax : (303) 342- comments electronically. ainvorthiness directive is in violation of this
1088: e-mail: roger. [email protected]. fo.-laiJ; Send comments to Docket section.
[jl For service information identified in this OperA.tions. M-30; U.S . Department of
AD. contact Univair Aircraft Corporation. Section 39.9 What if! operate an aircraft
Transportation. 1200 New Jersey or use a praduct that does not meet the
2500 Himalaya Road. Aurora. Colorado
80011: telephone: (303) 375- 8882. facsimile: Avenue, SE.. Room W12-140. West requirements of 8n airworthiness directi"e?
(303) 375--8888: Intemet: http:// Building Ground Floor. Washington. DC If the requirements of all ainvorthiness
univoirparts.com. You may review copies of 20590-0001. directive have not been met. you violate
the referenced service informatlon al the Hand Delivery or Courier: Bring § 39.7 each tlme you operate the aircraft or
FAA. Small Airplane Directorate. 901 Locust comments to Docket Operations in use the product.
Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page H–1

Federa l Register I Vol. 76, No. 72/Thursday, April 14. 20ll/Proposed Rules 20099
The majority we opinion is that the responsibilities placed on the FAA by These members believe that. given the
language of § 39.7. and its predecessor the Federal Aviation Act justify FAA's broad regulatory au thority, ADs
§ 39.3, imposes an operational mandate broadening the regulation [part 39] to may impose requirements that operators
that the requirements ofthe AD be make any unsafe condition . whether may not consider necessary and
maintained for each operation occurring resulting from maintenance, design, "directly related" to resolving the unsafe
after the actions requi red by the AD are defect. or otherwise, the proper subject condition.
accomplished. T hey conclude that o f an AD." (Amendment 39-106; 30 FR
Proposed Rcs (wnsc 2- Additional
§ 39 .9 expresses the well-established 8826. July 14. 1965). Prior to
legal poSition that for continuing Amendment3\J.-l06 ADs could not be Actions
operations of products that do not issued unless the unsafe condition was The FAA points to the langllage
comply with an AD. each flight is a related to a design feature. After contained in § 39.11 that answers the
separate violation. Amendment 39-106 ADs could be we's secoud quest ion.
The minority we opinion is that if issued for unsafe conditions however Section 39.11 What actioM do
the unsafe condition identified in the and wherever fou nd. The FAA d oes not ai rwo rthiness directives require ?
AD was fixed at a moment in time. then issue ADs as a sllbstitute for enforcing
§ 39.7 no longer applies. The conclusion Airworthiness directives specify
maintenance rules. If a mainteuance inspections you must carry out. conditions
of the we minority was that even i f the process is directly related to an unsafe and limitatIons you must comply with , and
product was determined to be in a condition. that maintenance action any actions you must take \0 resolve an
condition contrary to the requirements would be proper for an AD. Particularly unsafe condition.
of the AD at a later time. this change in for unsafe conditions resulting from
con fignration may be a violation of CFR First T itle 49. United States Code.
maintenance, it would be self-defeating
43.13(b). but not § 39.7. § 44701, establishes the F AA 's broad
to interpret § 39.7 as allowing reversion
stat utory anthority to issne regulations
to the same maintenance practices that
P roposed Response 1---Continuing in the interest of aviation safety, and the
Obliga tion ca used or contributed to the unsafe
issuance of an AD is an exercise of this
condition in Ule first place.
Section 39.9 notes the need for both authority. While describing the types of
initial action by the aircraft operator and Question 2-Additional Actions actions required by ADs. § 39.11 does
continued compliance by that aircraft Some members of the we questioned not limit the broad authority established
operator with the AD requirements. the extent of an aircraft operator's hy the statute. The reqUirements of the
Section 39.9 was added to the final rule obligation to accomplish actions AD are imposed by the language of the
in 2002 as a resu lt of comments that the referenced in an AD beyond those AD itself. and not by § 39.11. Thus an
proposed version of the rule language ac tions necessary to resolve the unsafe AD may require more actions than
combined compliauce and nOIl- condition specifically identified in an correcting the speCific unsafe conditi on.
compliance issues in one heading AD. An example would be an AD
(proposed § 39,5, final version is § 39.7 The opinion of these we members is requirement for certain continuing
of the 2002 rulemakingJ. The final rule that a reasonable interpretation of the maintenance actions to prevent or detect
p reamble stated that the agency added language in § 39,11 directing action to the unsafe condition in the fnture.
§ 39 .9 "to refer to § 39.7, which is the "resolve an unsafe condition" limits the In developing an AD. the FAA
rule that operators will violate if they FAA from requ iring actions that do "not exercises its discret ion in determining
fail to operate or use a prod uet without relate to correcting" the ideutified what actions are to be required in the
complying with all AD that applies to unsafe coudition . In other words. au AD interest of aviation safety . This
that product." is limited to those tasks tha t resolve the discretion is limited only by the
Section 39.9 explains the continuing unsafe condition, even if other tasks are Administrative Procedure Act's
obligation for aircraft operators to explicitly listed in the AD or in a prohibition on rulemaking actions that
maintain the AD-mandated referenced service bulletin (SB). Even if are ~arhitrary and capricious.n Provided
con figuration. Section 39.7 imposes an § 39.11 doesn't e xplicitl y limit the types the actions required by an AD are
operational requirement. Because the of actions tha t the FAA may mandate in reasonably related to the purpose of
AD imposes an enforceable reqUirement ADs. these members believe that ADs resolving the unsafe condi ti on, it is
to accomplish the mandated actions, the are limited to imposillg reqUirements within the FAA's discretion to mandate
only way to give § 39.7 any meaning is that are both necessary and "directly them . For example, service iuformation
to recognize that operators are required related" to addressing an unsafe frequently includes instructions for
to maintain the AD-mandated conditioll because that is the sole accessing the area to be worked on to
confignration . On ce the AD purpose of ADs. as defined in part 39. address the unsafe condition. Because
requiremeuts are lIlet au operator may The belief is Ulat this wonld allow an these access instrllctions are reasonably
only revert to normal maiutenance if operator to comply with those actions related to addressing the ullsafe
that maintenance does not result in that, in the operator's opin ion, correct condition, it is within the FAA's
changing the AD-mandated the unsafe condition without having to discretion to mandate them.
configu rati on . obtain an alternati ve means of We understand that some members of
The objective of part 39 and ADs compliance (AMOC) for other actions, the AD ARC believe that some ADs are
generally is not just to requi re such as access and close-up procedures, overly prescriptive with respect to
accom plishment of particular actions; it that are "not directly rela ted" to mandated actions that they believe are
is to ensure that, when prod uets are addressing that identified unsafe unnecessary to address the unsafe
operated. they are free ofidentified condition. condition. As explained previously,
unsafe conditions. Section 39.7 is the Other members of the 'vVG have the § 39.11 does not address this concern .
regulatory means by which the FAA opillion that § 39 .11 is merely Rath er. the rulemaking process by
prevents reintroduction of unsafe descript i\'e of the types of actions which individual ADs are ado pted
conditions. In 1965 the FAA recognized required by an AD; it neither imposes provides the public with an opportunity
that maintenance may be the cause of obligations on the operator nor limits to identify and comment upon these
some unsafe conditions: ~The the FAA's authority in issuing a n AD. concerns with each AD. In addition,

20900 Federal Register / Vol. 76, No. 72/Thursday, April 14. 20ll/Proposed Rules
each AD contains a provision allowing bulletin that are necessary to address unsa fe condition. Submit your request in the
for approval of an AM OC . wh ich allows the unsafe condition , and that operators manner described in §39.19.
operators to obtain relieffrom should not be required to accomplish
requirements they consider unnecessary any other actions that they determine If a change to II product makes it
or unduly burdensome. ace not necessary. is incorrect. Without impossible to comply with the
the modifier ~applicable. " the requirements of an AD. then the
Question 3- Use of the tenn operator must request an AMOC
~AppliCllble "
requirement to accomplish "all actions
specified in the service bu lletin ~ would approval.
A WC member cited the usc o f the literally mandate accomplishing all The FAA does not have the resources
term ~applicable" in a specific AD, AD ac tio ns. whether or not applicable to the to determine the modificatio n status of
2007-Q7-02 (72 FR 14400, March 26, configuration and condition of a every product to which the AD may
2007), which contains these particular airplane. The modifier apply. If it is impossible to co mply with
requirements: "applicable" is necessary to avoid this
(f) Within 60 months afte r the an AD as written. that does not mean
literal. but unintended and likely overly the product does not have the unsafe
effective date o f this AD: Modify the burdensome, meaning.
activation mechanism in the chemical condition. The only way to make sure
For e xample , in AD 2007-07-02 the product does not. or that there is
oxygen generator of each passenger different aclions are required depending
service unit (PSU) by doing alJ the another acceptable way to address it, is
on the cond itions fuund while
applicable actions specified in the to require an operator to obtain an
accomplishing the modification, The
Accomplishment InstmctioIlS of the AMOC approval.
adject ive, "applicable," is necessary to
applicable service bulletin specified ill limit the reqUired actions to those that For several yea rs before part 39 was
Table 1 of this AD. [Emphasis added .[ are indicated for the conditions found . revised in 2002 the FAA included a
The we member asked for an Note in every AD that contained the
The purpose of the phrase. "by
explanation ofthe FAA's use o f the
accomplishing all the applicable actions same substance as the regulation. This
word "applicable" in the two instances
specified," is to eliminate precisely the revisio n to the regulations was a result
of its nse in paragraph (f) of the AD.
ambiguity thftt would be introduced by of some operators claiming that an AD
Proposed Response 3- Use of the Term the we members' question. The did not apply to a particular airplane
"Applicable" operator is required to accomplish "all" because the airplane's configuration had
"Applicable" has the same meaning in the actions that are "applicable" to the changed. even though that airplane was
both places in paragraph (0. The second affected airplane. without allowing specifically identified in the
usage references Table 1 in the AD that discretion to determine which o nes are. "Applicability" paragraph of the AD. But
identifies the modeHs) of airplanes to in the operator's opinion, "necessary" to a change in product configuration docs
which each service bnlletin applies. So address t he unsafe condition . not necessarily mean that the unsafe
the Mapplicable service buHetin" is the Question 4- lmlJOssihilily condi tion has been eliminated. and in
one that applies to each corresponding some cases the nnsafe condition may
airplane model, as indicate d in the table A member of the AD ARC questions
actually be aggravated. So it is necessary
whether an AD needs to specifically
in the AD. Similarly, "all the applicable to emphasize that the ~Applicability"
address "impossibilities" (for example.
actions" speCified in each applicable paragraph o f the AD determines AD
service b ulletin are those actions that an AD requiring an action t hat is not
possible for the specific aircraft to applicability. not the configuration of an
are identified as applying to a part icular individual airplane. I n the case of the
which the AD applies, such as
airplane. "Applicable" is a necessary affected component having been
modifying parts that have been removed
qualifier in this context for two reasons: rem oved from the airplane. the operator
during an earlier alteration).
(1) In many ADs. the referenced service must obtain an AMOC approval. If the
bnHetins specify different actions for Proposed Response 4- lmpossibi lity removed component is replaced with a
different airplane configurations,
The FAA points to the language o f different component that mayor may
typically identified as "Gro up 1, Croup §§ 39,15 and 39.17 that answers the not retain the unsafe condition, this is
2,~ etc. (2) In many ADs. the referenced
fourth question. a technical issue that must be add ressed
service b ulletins specify different
actions depending upon conditions &oction 39.15 Does an airworthiness through the AMOC process. There are
found during accomplishment of directive apply if the product has been infinite variations on the "impossibility~
previous steps in the instructions, for changed? issue that cannot be anticipated when
example. if a crack is smaller than a Yes, an airworthiness directive applies to draft,ing an AD but for which the AMOC
specifIed size, repair in accoruauce with each product identified in the airworthiness process is well suited.
the Structural Repair Manual: if larger, directive, even if an individual product has
been changed by modifying, altering, or Issued in Washington. DC. on April 7,
repair in accordance wit h a method 2011.
repairing it in the area addressed by the
approved by the Aircraft Certification airworthiness directive, Rebecca n, MacPherson,
Office. So "applicable" limits the AD's
Sllcti on 39.1 7 What must 1 do if a chant:e Assistant ChiefCounse/ for Reau/alions.
requirements to only those that are
specified in the service bulletin for the in a product affucls my ability 10 a ccomplish IFR Doc. 2011 -8972 Filed ~- 13- 11; 8:,15 ami
the adions re1luired in an airworthiness BILU NG CODE ~ 9 ' ().-'3MP
configuration and conditions ofthe directive?
particnlar airplane. We intend for the
word "applicable" to limit the required If a change in a product affects your ability
to accomplish the actions requirod by the
actions to those that apply to the airwol1hinBss directive in any way, YOIl mllsl
particular airplane under the specific request FAA approval of an alternative
conditions found. method of compliance, Unless you can show
The opinion that "applicable" in this the change eliminated the unsafe condition,
context should be interpreted to refer your request should include the specific
only to t hose actions in the service actions Illat you propose to address Ille

30040 Federal Register /Vol. 76, No, 100/Tuesday, May 24, 20ll/Proposed Rules
(3) The NPPO must review and update the records each lime the traps United States unless the shipment is
maintain all forms and documents are checked. and make the records treated with an approved treatment
related to export program activities in available to APHIS upon request. The monitored by APHIS, Ifinspectors
places of production and packinghouses records must be maintained for at least (either from the exporting country's
for at least 1 year and, as requested, 1 year fur APHIS review, NPPO or at the U.s. pori of enlry) find
provide them to APHIS for review, (2) Pesl-free area for c. capitala. If the a single fruit fly larva in a shipment,
(b) Place of production requirements, pitaya fruit are prodnced in a place of they will reject the entire consignment
(1) The personnel conducting the production located in an area that is for shipment to the Uni ted States. and
trapping required in paragraph (c) of designated as free of C capitata in the place of production for that
this section mllst be hired, trained, and accordance with § 319,56-5, the s hipm ent will be suspended from the
supervised by the NPPO ofthe trapping in paragraph (cJ(1) ofthis export program until appropriate
exporting country, The exp::nting section is not reqnired for C. capitata. measures. agreed upon by the NPPO of
country's NPPO must certify that each (d) Packinghouse requiroments, (1) the exporting country and APHIS, have
place of production has effective fruit The packinghouses must be registered been taken,
fly trapping programs, and follows with the NPPO of the exporting country. (gl Commercial cOllsiSIlments. The
control guidelines, when necessary, to (2) All openings to the outside must pitaya fruit may be imported in
reduce quarantine pest populations, be covered by screening with openings commercial consignments only.
APHIS may monitor the places of of not more than 1,6 mm or by some (h) PhytosOllitary certificate, Each
production, other barrier that prevents pests from consignment of pitaya fruit mus! be
(2) The places of production entering the packinghouses, accompanied by a phytosanitary
producing pitaya fo r export to the (3) The packinlhonses must have
certificate issued by the NPPO oftbe
United States must be registered with double doors at t Ie entrance to the exporting country. containing an
the NPPO of the exporting country, facilities and at the interio r entrance to additional declaration stating that the
(3) Trees and other structures, other the area where the pitaya fruit are fruit in the consignment was produced
than the crop itself, must not shade the packed, in accordance with requirements in 7
crop during the day, No C, capilata or (4) While in use for packing pitaya
eFR 319,56- 51.
A iudens host plants may be grown fruit for export to the United States, the
within 100 meters of the edge ofthe packinghouses may only accept pitaya Done in Washington , DC, this 18th day of
May 2011,
production site, fruit that are from registered places of
(4) Pitaya fruit that has fallen on the production and that are prodnced in Kevin Shea,
ground must be removed from the place accordance with the requirements of Acting Administrator, Anima! and Plant
of production at least once every 7 days this section. Health Inspection Service.
and may not be included in field (e) Post-harvest procedures, The [FR Doc, 2011-12755 Fil<>d 5--23-11 ; 8:45 am]
containers offruit to be packed for pitaya fruit must be packed within 24 SllUNG C~ 3410-34_P
export, hours of harvest in a pest-exclusionary
(5) Harvested pitaya fruit must be packinghouse. Pilaya fruit must be
placed in field cartons or containers that packed in insect-proof cartons or DEPARTMENT OF TRANSPORTATION
are marked to show the place of containers that can be sealed at the
production, packinghouse, or covered with insect- Federal Aviation Administration
(c) Miligation measures for c. cupitata proof mesh or a plastic tarpaulin for
and A iudens, (1) Pest-free places of transport to the United States, These 14 CFR Part 39
production, (i) Beginning at least 1 year safeguards must be intact upon arrival
before harvest begins and continuing in the Un ited States. [Docket No. FAA-201G-1167]
through the end of th e shipping season, (0 Phytosanitary illspectioll. (1) The
trapping for A ludem and C. capitata NPPO of the exporting conntry mnst Proposed Airworthiness Directi ves
must be conducted in the places of visually inspect a biometric sample of Legallnterpretallon
pitaya fruit production with at least 1 pitaya fruit. jointly approved by APHIS AGENCY : Federal Aviation
trap per hectare of APHIS-approved and the NPPO of the exporting country, Administration, DOT,
traps, serviced every 7 days, fur D. neobrevipes and P. minor, and cut
(in From 2 montlis prior to harvest open a portion ofthe fruit to detect A ACTI ON: Extension of comment period
for a proposed airworthiness directives
through the end of the shipping season, ludens and C. capitola , If the fruit is
when lraps are serviced, if either A from a pest-free area for C capitata, legal interpretation.
ludeJls or C. capitata are trapped at a then the fruit will only be inspected for SUMMARY: The Federal Aviation
particular place of production at A.ludens, Administration published a proposed
cumulative levels above 0,07 flies per (2) The fruit are subject to inspection airworthiness directives legal
trap per day, pesticide bait treatments at the port of entry for all quaran tine interpretation for comment. In response
must be applied in the affected place of pests of concern, Shipping documents to several requests, we are extending the
production in order for the place of identifying the place(s) of production in comment period to allow additional
production to remain eligible to export which the fruit was produced and the time fur comment. Comments from the
pitaya fruit to the continental United packing shed(s) in which the fruit was public are requested to assist the agency
States. Ifthe average A /udens or C processed must accompany each lot of in developing the final legal
capitala catch is greater than 0.07 flies fruit presented for inspection at the port interpretation.
per trap per day for more than 2 of entry to the United States. This
consecutive weeks, the place of identification must be maintained nntil OATE S: Comments must be received on
production is ineligible for export until the fruit is released for entry into the or before June 30, 2011 .
the rate of cap lure drops to an average United States, ADDRESseS : YOIl may send comments
of less than 0,07 flies per trap per day, (3) If D. neohre\1pes or P. minor is identified by Docket Num ber F AA-
(iii) The NPPO must maintain records found, the entire consignment of fruit 2010- 1167 using any of the following
of fruit fly detections for each trap, will be prohibited from imiX'rt into the methods:

Federal Register /Vol. 76, No, 100/Tuesday, May 24, 20l1/Proposed Rules 30041
Federal eRulemoking Portai: Go to § 39.7 What is the legal effect offailing to changing the AD-mandated
http;//www.reguiations.govand follow com l,ly wi th an airworthiness dir ective? configuration.
the online instructions for sending your Anyone who operates a product that does The objective of part 39 and ADs
corn ments electronical ly. not meet the requirements of an applicable generally is not just to reqU ire
• Mail: Send comments to Docket airworthiness directive is in violation of this accomplishment of particular actions: it
Operations, M-30; U.S. Department of section. is to ensure that. when products are
§ 39.9 What if I operale an aircraft or use operated. they are free of identified
Transportation. 1200 New Jersey
a product that tiOI!S not meet the unsafe conditions. Section 39.7 is the
Avenue, SE .. Room W12-140, West requirements of an air wor thiness diredi ve?
Building Ground Floor. Washington. DC regulatory means by which the FAA
If the requirements of an airworthiness prevent.'> reintroduction of unsafe
20590-0001. directive have not been met. )'OU violate
• Hand Delivery or Courier: Bring conditions . In 1965 the FAA recognized
§ 39. 7 each time you operate the aircraft or
comments to Docket Operations in use the product. that maintenance illay be the cause of
Room W12-140 of the West Building some unsafe oonditions: "the
The majority WG opinion is that the responsibilities placed on the FAA by
Ground Floor at 1200 New Jersey
language of § 39.7. and its predecessor the Federal Aviation Act justify
Avenue. SE .. Washington. DC, between
§ 39.3, imposes an operational mandate broadening the regulation [part 39) to
9 a.m. and 5 p.m .. Monday through
that the requirements of the AD be make any unsafe condition. whether
Friday, except Federal holidays.
maintained for each operation occurring resulting from maintenance, design,
• Fax: Fax comments to Docket
after the actions reqnired by the AD are defect, or otherwise, t he proper subject
Operations at 202--493-2251.
accomplished. They conclude that o f an AD." (Amendment 39-106; 30 FR
fOR FURTHER INfORMATION CONTACT: John § 39.9 expresses the well-established 8826, July 14. 1965) . Prior to
King. Staff Attorney. Regulations legal position that for continuing Amendment 39-106 ADs could not be
Division. Office ofthe ChiefCollnse\' operations of prod ucts that do not issued unless the unsafe condition was
Federal Aviation Administration, 800 comply with an AD. each flight is a related to a design feature. After
Independence Avenue. SW., separate violation. Amendment 39-106 ADs could be
Washington. DC 20591; telephone: 202- The minority WG opinion is that if issued for unsafe conditions however
267-3073. the nnsafe condition identified in the and wherever found. The FAA does not
SUPPLEMENTARY IN fORMATION: AD \Vas fixed at a moment in time, then issue ADs as a substitute for enforcing
§ 39.7 no longer applies. The conclusion maintenance rules. If a maintenance
Background
o Hhe WG minority was that even ifthe process is directly related to an unsafe
On April 14, 2011. the Federal product was determined to be in a condition. that maintenance action
Aviation Administration (FAA) oondition contrary to the reqnirements would be proper for an AD. Particularl y
published a proposed airworthiness of the AD at a later time, this change in for unsafe conditions resulting from
directives legal interpretation in the con figuration may be a violation ofCFR maintenance, it would be self-defeating
Federlll Reg ister for comment (72 FR 43.13 (b), but not § 39.7. to interpret § 39.7 as allowing reversion
20S\1S). The FAA received numerous to the same maintenance practices that
Proposed Response 1-Continuing
comments by the close of the oomment cansed or contributed to the unsafe
period on May 16, 2011. Included in the Obligation
condition in the first place.
comments were requests to extend the Section 39.9 notes the need for both
comment period to allow additional ini tial action by the aircraft operator and Q uestion 2-Additional Actions
time for comment. The FAA is granting continued compliance by that aircraft Some members of the WG questioned
an extension until June 30, 20 11. for the operator with the AD requirements. the extent of an aircraft operator's
public to review the proposed Section 39.9 was added to the final rule obligation to accomplish actions
interpretation and provide comments. in 2002 as a result of comments that the referenced in an AD beyond those
We are repeating the publication of the proposed version of the rule language actions necessary to resolve the u nsafe
proposal for the convenience ofthe combined compliance and non- condition specifically identified in an
reader. compliance issues in one heading AD.
(proposed § 39.5, final version is § 39.7 The opinion of these WG members is
The Rel/uest o r the 2002 rule making). The final rule that a reasonable interpretation of the
The F AA's Organization/Procedures preamble stated that the agency added language in § 39.11 directing action to
Working Group (WG) of the § 39.9 "to refer to § 39.7. which is the "resolve an unsafe condition» limits the
Airworthiness Directive Implementation rule that operators will violate iflhey FAA from requiring actions that do "not
Aviation Rulemaking Committee (AD fail to operate or use a product without relate to correcting" the identified
ARC) requested that the FAA provide a oomplying with an AD that applies to unsafe condition. In other words. an AD
legal interpretation of several provisions that product." is limited to those tasks t hili resolve the
in 14 Code of Federal Regulations (CFR) Section 39.9 explains the continuing unsafe condition. even if other tasks are
that would help resolve a number of obligation for aircraft operators to expliCitly listed ill the AD or in a
issues that have been debated within the maintain the AD-mandated referenced service bulletin (S8). Even if
WG. These issues partly result from configuratio n. Section 39.7 imposes an § 39.11 doesn't explicitly limit the types
certain changes made in the plain operational requirement. Because the o f actions thftt the FAA may mllndate in
language revision to CFR part 39 in 2002 AD imposes an enforceaule requirement ADs. these memUers believe that ADs
(see 67 FR 47998. July 22. 2002). to accomplish the mandated actions. the are limited to imposing requirements
only way to give § 39.7 any meaning is that are both necessary and "directly
Ques tion l -Conlinuing Obl iga tion related" to add ressing an unsafe
to recognize tha t operators are required
Some members of the WG question to maintain the AD-mandated condition because that is the sole
the extent of an aircraft operator's con figuration . Once the AD purpose of ADs, as defined in part 39.
continuing obligation to maintain an requirements are met an operator may The belief is tllat this would allow an
AD-mandated oonfiguration . They ask only revert to normal maintenance if operator to comply with those actions
about two regulations: that maintenance does not resu It in that. in the operator's opinion . correcl

30042 Federal Register /Vol. 76, No, 100/Tuesday, May 24, 20ll/ Proposed Rules
the unsafe condition withont havi ng to We understand that some members of requirements to only those that are
obtain an alternative means of the AD ARC believe t hat some ADs are specified in the service bulletin for the
compliance (AMOC) fur other actions, overly prescriptive wi t h respect to configuration and cond itions ofthe
such as access and close-up proced ures, mandated actions that they believe are particular airplane. We intend for the
that are Mnot d irectly reltlted~ to unnecessary to address the unsafe word ~applicable" to limit the required
addressing that identified unsafe condition. As explained previously, actions to those that apply to the
condition, § 39.11 does not address this concern. particular airplane under the specific
Other members ofthe we have the Rather. the rulemaking process by condi tions found.
opinion that § 39, 11 is merely which individual ADs are adopted The opinion that "applicable" ill this
descriptive of the types of actions provides the public with an opportunity context shoul d be interpreted to refer
required by an AD; it neither imposes to identify and comment upon these only to those actions in the service
obligations on the operator nor limits concerns with each AD. In addition, bulletin that are necessary to address
the FAA's authority in issuing an AD, each AD contains a provision allowing the unsafe condition. an d that operalors
These members believe that given the for approval of an AMOC, which allows should not be required to accomplish
FAA's broad regulatory authori ty, ADs operators to obtain relief from any other actions that they determine
may impose requirements that operators requirements they consider unnecessary are not necessary. is incorrect. Without
may not consider necessary and or unduly burdensome . the modifier "applicable." the
~directly related" to resolving the unsafe requirement to accomplish "all actions
condition, Question 3- Use of the Term
"Ap plica ble" specified in the service bulletin" would
Proposed Response 2- Addi tiono l literally mandate accomplishing all
A WG member cited the use of the actions, whether or not applicable to the
Actions term "applicable" in a specific AD, AD configuration and condition of a
The FAA points to the language 2007-07-02 (72 FR 14400. March 28, particular airplane. The modifier
contained in § 39. 11 that answers the 2007), which contains these "applicable" is necessary to avoid this
WG's second question. requirements: literal, but unin tended and likely overly
§ 39.11 What ~ cti on s do airwort hiness (0 Within 60 months after the effective burdensome. meaning.
directi vllS requi re? date oftllis AD: Modify the activation For example, in AD 2007-07-02
Airworthiness directives specify mechanism in the chemical oxygen generator different actions are required depending
inspections you must carry out. conditions of Bach passen!er service unit (PSUJ by doing on the conditions found while
and lunitations you must comply with, and a11 the applJea Ie actIOns specified in the accomplishing the modification. The
any actions you IIRlst take to resolve an AlXOmplishment InsfI'nctiQns o/the
unsafe condition, applicable service buJJetin specified in Table adjedive. ~applicable." is necessary to
J a/this AD. IEmphasis added. I limit the required ac tions to those that
First Title 49. United States Code. are indicated fur the conditions fuund.
§44701. establishes the FAA's broad The WG member asked for an The purpose of the phrase, ''by
statutory authority to issue regulations explanation of the FAA's use of the
accomplishing all the applicable actions
in the interest of aviation safety, and the word "applicable" in the two instances specified," is to eliminate preCisely the
issuance of an AD is an exercise of this ofits use in the paragraph (0 ofthe AD. ambigui ty that would be introduced by
authority. While describing the types of ProlJosed Res ponse 3- Use oflhe Tenn the WG members' question. The
actions required by ADs, § 39.11 does MApJllicable" operator is required to accomplish ~alP
not limit the broad authority established the actions that are "applicable" to the
by the statute. The requirements of the ~Applicable" has the same meaning in
AD are imposed by the language of the both places in paragraph (0. The second affected airplane. without allowing
usage references Table 1 in the AD that discretion to determine which ones are,
AD itself, and not by § 39 .11. Thus an in the operator's opinion, "necessary" to
AD may require more actions than identifies the model(s) of airplanes to
which each service bulletin applies. So address the unsafe condition.
correcting the specific unsafe condition.
An example would be an AD t he "applicable service bulletin" is the Q uestion 4- lm possibility
requirement for certain continuing one that applies to each corresponding A member of the AD ARC questions
maintenance actions to prevent or detect airplane model. as indicated in the table whether an AD needs to speCifically
the unsafe condition in the future. in the AD. Similarly. ~all the applicable address "impossibilities" (for example.
In developing an AD. the FAA actions" specified in each applicable
an AD requiring an action that is no t
exercises its discretion in determining service bulletin are those actions that possible for the specific aircraft to
what actions are to be required in the are identified as applying to a particular which the AD applies, such as
interest of aviation safety. This airplane. "Applicable" is a necessary
modifying parts that have been removed
discretion is limited only by the qualifier in this context fur two reasons: during an earlier alteration).
Administrative Procedure Act's (1) In many ADs. the referenced service
prohibition on rulemaking actions that bulletins speCify different actions for P ro posed RcsIHlnse 4-1mlJOssibility
Hre "arbitrary and cH\',ricious ." Provided different airplane configurations, The FAA points to the language of
the actions required y an AD are typically identified as "Group 1. Group §§ 39.15 and 39. 17 that answers the
reasonably related to the purpose of 2," etc. (2) In many ADs. the referenced fourth question .
resolVing the unsafe condition. it is service bulletins specify differen t
§ 39.1 5 Docs an airworthiness directive
within the FAA's discretion to mandate ac tions depending upon conditions IIIJIJly if the Ilfodu ct has been changed ?
them. For example. service information found during accomplishment of
previous steps in the instructions. for Yes. an airworthiness directive applies to
frequen tly includes instructions for each product identified in the airworthiness
accessing the area to be worked on to example. if a crack is smaller than a directive. even if an individual product has
address the unsafe condition. Because specified size, repair in accordance with been changed by IOOdifying, altering, or
these access instructions are reasonably the Structural Repair Manual; if larger. repairing il in the area addresood by the
related to addressing the unsafe repair in accordance with a method ainvorthiness directive.
condition. it is within the FAA's approved by the Aircraft Certification § 39.1 7 Whalmuslldoifachangeina
d iscretion to mandate them. Office. So "applicable" limi ts the AD's prod uct affects my abili ty to llccomplish the

Federal Register /Vol. 76, No, 100/Tuesday, May 24, 20ll/Proposed Rules 30043
actions required in an airwo rthiness DEPARTMENT OF TRANSPORTATION lIlay review copies of tile referenced
directil'e? service information at the FAA.
If a change In a product affect;; your ability Federal Av iation Administration Transport Airplane Directorate, 1601
to accomplish the actions required by the Lind Avenue. SW .. Ren ton. Washington.
airworthiness directive in any way, you must 14 CFR Part 39 For information on the availability of
request F' AA approval of an alternative [D ocket No. FAA-201 t -0475; Directorate this material at the FAA, call 425-227-
method of compliance, Unless you can show IdentHier 201 G-NM-199-ADJ 1221.
the change eliminated the unsafe condilion,
your request should include the specific RtN 212G-AA64 Examining the AD Docket
actions that you propose to address the You may examine the AD docket on
Airworthiness Directi v es; The Boeing
unsafe condi tion, Submit your request in the the Internet at http://
manner described in §39,19 Company Model 757 AIrplanes IVlvw.reguiatiolls.gov; or in person at the
AGENCY :Federal Aviatiou Docket Management F'acility between
If a change to a product makes it Administration (FAA). DOT. 9 a.m. and 5 p.m., Monday through
impossible to comp ly with the F'riday. except Federal holidays. The AD
requirements of an AD, then the ACTION:Notice of proposed rulemaking
(NPRM). docket contains this proposed AD. the
operator must reqnest an AMOC regulatory evaluation. any comments
approvaL SUMMARY: We propose to adopt a new received, and other information. The
The F' AA does no t have the resources airworthiness directive (AD) for the street address for the Docket Office
to determine the modifica tion status of products listed above. For certain (phone: 800-647-5527) is in the
every product to which the AD may airplanes, this proposed AD would ADDRESSES section. Comments will be
apply, If it is impossible to comply with reqUire the installation of llew relays available in the AD docket shortly after
an AD as written, that does not mean adjacent to two of the spoiler control receipt.
the product does not have the unsafe modules that would prevent the FOR FURTHER INFORMATION CONTACT:
condition, The only way to make sure deployment of certain spoiler pairs Marie Hogestad. Aerospace Engineer.
the product does not, or that there is when Iftnding flftpsare selected. F'or Flight Controls, ANM-130S, Seattle
another acceptable way to address it, is certain other airplanes. this proposed Aircraft Certification Office (ACO).
to reqnire an operator to obtain an AD would require torqUing the bracket FAA. 1601 Lind Avenue. SW .. Renton.
AMOC approvaL assembly installation nuts and ground Washington 98057-3356; phone: 425-
F'or several years before part 39 was stud nuts. and doing bond resistance 917-6418; fax: 425-917-6590; e-mail:
revised in 2002 the FAA included a tests between the bracket assemblies [email protected].
Note in every AD that contained the and the terminal lugs on the ground SUPPLEMENTARY 1NFORMATlON:
same substance as the regulation, This studs. This prolX'sed AD is prompted by
revision to the regulations was a result numerous reports of unintended lateral Comments Invited
of some operAtors claiming that al) AD oscillations during the final approach . We invite you to send any written
did not apply to a particular airplane just before landing. We are prolX'sing relevant data. views, or arguments about
because th e airplane's configuration had this AD to reduce the chance of this proposal. Send your comments to
changed, even though that airplane was unintended lateral oscillations near an address listed under the ADDRESSES
specifically identified in the touchdown. which could result in loss section . Include "Docket No. F'AA-
"Applicability~ paragraph of the AD, But oflateral control ofthe airplane. and 2011-0475; Directorate Identifier 2010-
a change in product configuration does consequent airplane damage or injury to NM_199-ADn at the beginning o f your
not necessarily mean that the unsafe flight crew and passenb-'efS. comments. We specifically invite
condition has been eliminated, and in OATES : We must receive comments on comments on the overall regulatory.
some cases the unsafe condition may this proposed AD by July 8. 2011. economic, environmental. and energy
actually be aggravated. So it is necessary ADDRE SSES: You may send comments by aspects of this proposed AD. We will
to emphasize that the "Applicability" any of the following methods: consider all comments received by the
paragraph of the AD determines AD • Federal eRuJemaking Portal: Go to closing date and may amend this
applicability, not the con figuration of an lr!tp://www.regulalions.gov. F'ollow the proposed AD because of those
individual airplane. In the case of the instructions for submitting comments. comments.
affected component having been • Fax; 202-493-2251. We will post all comments we
removed from the airplane. the operator • Mai}; U.S. Department of receive. without change. to http://
must obtain an AMOC approval. If the Transportation. Docket Operations. IVww.regulatiolls.gov, including any
removed component is replaced with ft M-30. West Building Ground Floor, personal information you provide. We
different cOllllX'nent that lIlay or may Room W12-140, 1200 New Jersey will also post a report summarizing each
not retain the unsafe condition. this is Avenue. SE.. Washington. DC 20590. substantive verbal contact we receive
a technical issue tha t must be addressed • Hand Delivery: Deliver to Mail about this prolX'sed AD.
through the AMOC proct!ss. There are address above between 9 a.m . and
infinite variations on the "imlX'sSibility" 5 p.m .. Monday through Friday. except Discussion
issue that cannot be anticipated when Federal holidays. We have received numerous reports of
drafting an AD but for which the AMO C For service information identified in Boeing 757 events where the flight
proct!ss is well suited. this proposed AD. contact Boeing crews experienced unintended lateral
IS6Ue(\ in Washinglon. IX. on May 18,
Commercial Airplanes, Attention: Data oscillations during the final approach.
& Services Management, P.O. Box 3707, just before landing. On e event resul ted
2011.
MC 2H-65. Seattle, Washington 98124- in a nose gear collapse after a hard
Rebet;ca B. MacPhe rson.
2207: phone: 206-544-5000. extension Iftnding and another event resulted in ft
Assistan t Chief CoulISeJ for Regulations. 1: fa.'\: : 206-766-5680: e-mail: tail strike during a landing that was
[FR Doc;. 201 1_ 12733 FiI.,.! 5_ 23-1 I; 8 ,45 am] [email protected]; Internet: aborted because ofthe oscillations. The
BILUNG COOE 4 ~lO-'3-P https://www.myboeingfleet.com. You oscillations are characterized by large

Federal Aviation
Administration
Memorandum
Date: SEP 01 2010
To: Rebecca MacPherson. Assistant Chief Counsel for Regulations. AGC-200
From: Steven Dou!,~epu~pivision Manager. Aircraft Maintenance Division.

AFS-30Ia p---
Subject: Request for Interpretation 14 CFR sections 39.7. 39.9 and 39.11
The Federal Aviation Administration (FAA) Organization/Procedurcs Working Group (WG) of

the Airworthiness Directive Implcmentation Aviation Rulcmaki ng Com mittee (AD ARC)
believes that an interpretation of 14 Code of Federal Regulations (eFR) sections 39.7. 39.9. and
39.11 would help resolve a number of issues that have been debated withi n the WG.
These issues result from certain changes made in the "plain language" revision to part 39 in
2004. Specifically WG members expressed divergent opi nions regarding the verb usage and
tense in the current "plain language" version of part 39.
The sections that are particularly troublesonte are presented below. with the "old" version (where
applicable) in italics.
( I) Section 39.11 What actions do ai rworthiness directives require? Airworthiness

directives specify inspections YOli must carry Ollt, conditions and limitations you
must co mply w ith. and any acti ons you must take to resolve an un sa fe co ndition.
Section 39. J J Applicability. This subpart idel1lifies those products in which the
Administrator has found an unsafe condition as described in Sec. 39. J and. as
appropriate. prescribes inspections and the conditions and limitations, if tiny,
IInder which those products lIlay continue 10 be operated
One opinion is that a reasonable interpretation of the language directing action to

"resolve an unsafe co ndition". lim ited the agency from requiring acti ons that did not
relate to correcting the identified unsafe cond ition. In other word s. an AD is limited to
those tasks lhat resolve the unsafe condition. whether the tasks are explicitly listed in the
AD or part of a referenced service bu lletin (S B).

2
(2) Section 39.9 What if I operate an aircraft or use a product that does not meet the
requirements of an airwonhiness directive? IJ the requirements of an
airworthiness directive have not been met, you violate § 39. 7 each time yotl
operate the aircraft or use the product.
One opinion is that the use of the words "have not been met" indicated that "if' the
unsafe condition was indeed fix ed at a moment in time, this section of the regulations d id
not apply. In other words, if the AD was at onc time complied w ith as required by
section 39.11. this section could not be applicable. The conclusion of the posit ion was
this regulation pointed to a spec ific moment in time, i.c .. once the unsafe condition wa s
corrected. the regul ation no longer applied, eve n if the product was detemlined 10 be
conlrdry tu the requin:melll:S uf tht: AD at a later lilll!;. If the product wa:s operated "out
of configuration", then secti on 43.13(b) would bc vio latcd, not scetion 39.7.
The other opinion is that the language of section 39.7 (as well as its earl ier version, i.e.,
section 39.3) impose s an operational mandate that the requirements of the AD be
maintained for each opcmtion occurring aOcr the action:s rt:quirct.l by the AD arc
accomplished.
In other words, this sect io n simpl y ex presses the we ll establi shed legal conclusion that,
for continuing operations of products that do not comply with ADs, each fligh t is a
separate vio lation. The emphasis on verb tense is misplaced ; if a product once complied,
but for whatever reason no longer comp li es. the requirements of the AD " have not been
met" when the product is operated o n that particular flight.
(3) Section 39.7 What is the legal effect of failing to comply wi th an airwo rthiness
directive? Anyone who operates a pmduct that does not meet the requi rements of an
appl icabl e airworthiness directive is in violation of th is section.
Seclion 39.3 General. No person may operate (J product to which an airworthiness

directive llpplies excepi in accordance with the "equirements of rhar airworthiness
directive.
This section was not discllssed with as much vigor as secti on 3Q.9; the language in both
the o ld and new version indicates that the product must comply with the AD whenever it
is operated or a violation will result.
Please advise the WG which of the above opin ions is correct and provide whatever additional
guidance on the meaning of each section that you thin k may he useful.

FI~~FI
121 North Henry Street
ftJexandria, VA 22314-2903
T: 7037399543 F: 703 739 9488
[email protected] www.arsa.org
Aeronautical Repair Station Association
MEMORANDUM
TO: Airworthiness Directive Implementation Aviation Rulernaking Committee
FROM: Sarah MacLeod

Executive Director
Aeronautical Repair Station Association
DATE: August 31,2010
RE: Additional Issues to Consider Regarding 14 CFR part 39 Compliance

Recommendation 12
During the deliberations on how to address recommendation 12, several underlying issues were brought to
my attention as the point of contact for the sub-group working the matter.
Since the sub-group and the Working Group did not participate in discussing these issues, it was
determined they should not be part of the Summary Report. However, the industry requested that they be
brought to the ARC's attention since it was believed they are some of the underlying reasons that the
FAA and industry are having compliance and enforcement difficulties with part 39.
"AD-Friendly" Service Bulletins
The industry raised the issue of whether the advent of "user-friendly" and/or "AD-friendly" service
bulletins may have contributed to the current compliance issues. The airlines noted that compliance
issues and the need for AMOCs have increased significantly over the past decade. It is during this time
that the "AD-friendly" service bulletins were introduced.
It is believed that the basis for "AD-friendly" service bulletins was to alleviate differences between AD-
mandated actions and actions that may have been accomplished in accordance with service bulletins
issued prior to the AD compliance requirement.
However, this effort may have resulted in unintended consequences. Namely-
• Did the adoption of "AD-friendly" wording inadvertently increase the scope of ADs beyond the
requirements necessary to fix or address the unsafe condition, i.e., the "safety intent''? It seems that
"AD-friendly" mandates the entire service bulletin, whereas prior to "AD-friendly", the corrective
actions for the safety issues were specifically identified.
• Similarly, have service bulletins become more encompassing?
Therefore, it is believed that the ARC should request a comprehensive review of the concept and
understanding of the "AD-Friendly" service bulletin process to determine whether its adoption
inadvertently increase the scope of ADs beyond those actions essential to address the defined unsafe
condition.

MEMORANDUM
DATE: August 3 1, 2010
PA GE: 2
RE : Additional Issues to Consider Regarding 14 CFR part 39 Compliance
Recommendation 12
Use o/the Word "Applicable "
One difficulty for operators is how to interpret the word "applicabl e" when it is used in relation to a
service bulletin incorporated by reference.
The particular exampl e of AD 2007-07-02 was used to illustrate the different approaches that can be taken
when attempting to interpret exactly what must be accompli shed by the operator in order to establish
complian ce with the AD.
In this parti cular case, the agency's final mle defined the unsafe condition as:
(d) This AD results from several reports indi catin g that some chemi cal oxygen generators fail ed to
acti vate during in-flight decompress io n events. TIlese failu res were due to fracture of components
between the passenger oxvgen mask and the release pin in th e oxvgen generator. We are issuing
this AD to prevent failure of th e activation mechanism of the chemi cal oxygen generator, which
could result in the unavailability of supplemental oxygen and possibl e incapacitation of passengers
and cabin crew during an in-fli ght decompress ion. Emphasis added. (S ec, 72 FR 14402, (March
28, 2007).)
111e agency's notice of proposed rulemaking specifically described the e>..1 ent and nature of the issue that
was creating th e unsafe condition. The " Discuss ion" section of the notice stated:
We have rece ived several reports indicating that some chemical oxygen generators fail ed to activate
during infli ght decompression events . These failures were due to fracture of components between the
passenger oxygen mask and the release pin in the oxygen generator. 1110 release pin must be pulled
out of the oxygen generator firing mechanism to activate the generator. TIle fractures occur when a
passenger en counters resistance when attenlpting to pull down the oxygen mask. 111e system is
designed so that when a mask is pulled down for dOJUling, a lanyard attached to the mask pulls down
on a release cable within the passenger service unit (PSU). The release cabl e is attached to a pin in the
oxygen generator firin g mechani sm. Downward pressure appli ed on the rel ease cable when the mask
is pulled down ca uses the pin to be pulled Ollt of the firin g mechanism, acti vating the generat or and
starting the flow of oxygen to the masks. If excessive resistance occurs when pulling down the mask.,
the components between th e mask and the generator release pin can break, such as the tab that
connects the oxygen mask to the lanyard or the ring that attllches the lanyard to the release cable.
Failure of the activation mechanism of the chemical oxygen generator could result in the
unavai lability of supplemental oxygen and possible incapacitati on of passengers and cabin crew
during an inflight decompression. (See, 71 FR 39593, (July 13, 2006). )
111e Compliance section of the AD states :
(e) You are responsible for having the actions required by this AD perfonlled within the compliance
times specifi ed, unless the actions have alreadv been done. (See, 72 FR 14402, (1 Iarch 28, 2007). )
l
(Emphasis added. )
TIle Modification section of the AD states:

MEMORANDUM
DATE : August 31, 20 10
PAGE: 3
Recommendation 12
(f) Within 60 months after the effective date of thi s AD: ~i[odify the activation mechanism in the
chemi cal oxygen generator of each passenger service unit (PSU) by doing all the appl icable
actions specified in the Accomplishment Instructions of the applicable service bulletin spec ified in
Table 1 of this AD. (See, 72 FR 14402, (March 28, 2007).)
Table 1 sets forth different service bulletins for the variolls model s of aircraft as follows:
Boeing special attention Service Dated Applicabl e to modeVseries

Bulletin
1545 , 8, 2005 ·700 - 800, and - 900

; 22,2005 , -400, and - 500
2: 2005 757-20C
2: 2005 757-30C
A query was made as to exact ly what the word "applicable" was referring to in the two instances of its use
in the " Modification" paragraph of the A D.
111ere seems to be two possibilities:
( I) Appl ying a narrow read of th e words, one could com e to the conclusion that the first applicab le
referred to actions specified in the Accomplishment lnstmctions that wo uld modify the acti vation
m echanism (correct the identified unsafe condition); the second applicab le referred to the service
bulletin relating to the parti cular model and seri es upon which th e modifi cation was being made.
This narrow read of the tenns allows the operator to compl y w ith those actions that correct the unsafe
condition without having to obtain an AMOC for actions that are "not applicable" to addressin g that
identified conditi on. If this is not the proper " interpretation" of the first usage of the ternl
"applicabl e", then that word shou ld be removed because the Modification paragraph really requires
the petfonnance of "all the actions specified in the Accomplislunent Instmctions of th e applicab le
service bulletin spec ifi ed in Tab le 1 of ltheJ AD. "
(2) Appl ying a broad read of the words, the teml appli cable is beli eved to have the same m eaning in both
instan ces. Th e second usage references a tabl e that identifi es the Illodel(s)/seri e(s) of a irpl anes to
wh ich each service bulletin applies. So th e "app li cabl e service bulletin " is the one that applies to each
corresponding airplane model, as indicated in the table.
Similarly, the "appl icabl e actions" spec ified in each service bulletin are th ose actions that are
identified as applying to a particular airplane.
" Appli cable" is a necessary qualifi er in this context for two reasons: (I) bl many ADs, th e referenced
service bulletins specify different actions for different airp lane configurations, typically identifi ed as
" Group I, Group 2," etc. (2) In many ADs, the referenced scrvice bullctins specify different actions
depending upon conditions found durin g accomplislUllent of previo us steps in the instructions, e.g., if

MEMORANDUM
DATE: August 3 1, 20 10
PAGE: 4
Recommendation 12
a crack is smaller than a specified size, repair lAW the SRM; if larger, repair lAW a method approved
by the ACO. So "appli cabl e" limi ts the AD's requirements to only those that are specifi ed in the
service bulletin for the confi guration and conditions or the pm1ic ul ar airplane.
The positi on that "appli cable" in thi s contex1 should he interpreted to re fer onl y to those acti ons in the
service bulletin that are necessary to address the unsafe condition, and thai operat ors should not be
required to accomplish any other actions that they detennine are not necessary would be incorrect.
It is believed that this approach would be inconsistent with the intent of the ADs and wo uld result in
inconsistent rmd potentially unsafe implement ation of AD requirements. Because operat ors typicall y
are 110t familiar with the underl ying reasons for particular provisions in service bulletins, they may
ident ify as not "applicab le" actions that , in fact, are necessary to adequately address the unsafe
condition, thereby potenti ally defeating the purpose of the AD. This woul d also jeopardize the
enfo rceability of ADs by allowing operators to choose whi ch act ions are necessary for compli ance.
Finally, this approach would violat e a basic legal principle of regulatory constmction that a term used
more than once is presumed to have the same meaning unless it is apparent that it has a different
meanin g in different cont exts.
'Ole second possible explanation of the use of the tenn "applicable" twice in the context of this particular
AD seemed to some, to be probl emati c under general ml emaking prin ciples. First, the under the broad
intellJretation, the use of th e initial "applicable" adds no va lue to the senten ce. In other words, if the
service bulletins already separate actions that are and/or are not applicable based on conditions, groups,
etc., the additi on of the ternl doesn 't add value or meaning. Indeed, it in vites confusion since it indi cates
there may be additional "non-applicabl e actions" to th ose in the service bulletin but not itemized by the
AD.
Second, the belief that the "operators typi cally are not familiar with the underlying reasons fo r parti cul ar
provisions in service bulletins" is contrary to a full understanding of the regul ation under whi ch
complian ce is expected. TIl e AD process is a special and very powerful ml emaking activity with a very
narrow appli cati on. Th ere should be no "secret science" to the description of th e unsafe conditi on or to
th e exact requirements needed to address that condition. If a service bulletin in unclear on exactly what is
required to address the unsafe condition, the agency has put itself and the publi c in a problematic
enforcement and compliance position. Most persons responsible for AD compliance are not lawyers <md,
indeed, reasonable lawyers disagree on the use of the tenn in the context presented. 'nle agency's rules
should be clear 0 11 th eir face and should not take interpretation from the FAA or the public for
complian ce.
111ird, the basic legal principle of regulatory construct ion that a ternl used more th an once is presumed to
have the same meaning unless it is apparent that it has a different meaning in different cOllte:-.1 s is also
prob lemati c in this case. 'nle specifi c sentence at issue is " lmJ odify the acti vation mechmlism in the
chemical oxygen generator of each passenger service unit (PSU) by doing all the applicable acti ons
specifi ed in the Accompli shment InstHictions of the applicabl e service bull etin specifi ed in Table 1 of thi s
AD. " It is not unreasonabl e to concl ude from the senten ce 's context that the fi rst use of the teml
"applicabl e" refers to the acti ons necessary to "modify the acti vation mechanism" and th e second

MEMORANDUM
DATE: August 3 1, 20 10
PAGE: 5
RE: Add itional Issues to Consider Regarding 14 CFR part 39 Compliance
Recommendation 12
"applicable" is referring to the service bull etin that li sts different makes and models of aircraft. TIlis is
particularl y tme in thi s situation sin ce '"the applicable actions specifi ed in the Accompli shment
Instructions" o r each serv ice bulletin which m odifi es the acti vation mechani sm are the srune.
Finally, the service bulletins were issued alm ost two years prior to the AD. The accomplishment of the
" applicable actions" under part 43 allows the operator to m odify the activation m echani sm in accordance
w ith its general maintenance procedures. hI this case, the PSU would have been removed from the
aircraft and the unsafe condition specifically discussed in the preamble and included in the final rule
wo uld have been addressed in the shop environm ent. Indeed, operators could reasonably conclude that
the FAA would know that PS Us typicall y go to a shop during schedu led aircraft maintenance (rat her than
having maintenance perfonned on the aircraft) b y adding the first " applicable" to the AD 's instructi ons.
While a change to part 39 would not address thi s issue, the industry is concemed that these types of issues
are creat ing complian ce and enforcem ent probl ems. TIl erefore, the industry believes that the ARC should:
• Request the FAA develop a legal opinion or enforcement policy regarding the nature and extent of
part 39 rulemaking activ ity. Although the agency has general rui emaking authority regarding aviation
safety, part 39 appears to be reserved for those instances where a specifi call y definable unsafe
condition in a parti cular product must be addressed. The industry has expressed the belief thai ADs
sh ould be limit ed to the specifically defined unsafe conditi on lUld those actions necessary to address
those unsafe conditions. In other words, if an AD contains action that is not directly related to
addressing the defined unsafe condition, it wo uld make the rule and its enforcement problematic.
In addition to the items 0 11 the Recommendation 12 summary sheet, the industry al so believes that the
ARC sh ould :
• Request an evaluation of the use of the tenn "t em linating action" to ensure that it does in fact bring an
end to any AD-related requirements with respect to the particular un safe condition so that operators
blOW that they can put that aspect back into the "nonnal " maintenance program.

From AD ARC Meeting December 14 and 15, 2010
Action Item: Rebecca MacPherson (AGC–200) to talk to Peter Lynch (AGC–30052) to

determine if AMOCs are required to address impossible actions mandated by the AD (for
example, if SB calls out an action that physically cannot be done for some reason).
(Action Item No. 2010–12–08)
52
Assistant Chief Counsel for Enforcement.

APPENDIX I—LIST OF AD ARC DELIVERABLES
The listed documents support the majority of the primary implementation actions
described in this report. You may view or obtain copies of these documents from the
Web sites as indicated.
 FAA Order 8900.1, Flight Standards Information Management System;
(http://rgl.faa.gov):
o Aviation Safety Inspector Decisionmaking, Volume 3, Chapter 60, Section 1
(April 23, 2011);
o Aircraft Evaluation Groups, Volume 8, Chapter 2, Section 2 (June 20, 2011);
o Aircraft Evaluation Group Outreach in the Airworthiness Directives Process,
Volume 8, Chapter 2, Section 9 (June 20, 2011);
o Requesting 24/7 Support for AMOCs , Volume 3, Chapter 59, Section 4
(April 12, 2011);
o Processing Alternative Methods of Compliance Proposals to Airworthiness
Directives, Volume 3, Chapter 59, Section 3 (April 12, 2011);
o Processing an AMOC Proposal, Volume 3, Chapter 59, Section 2
(April 12, 2011);
o Evaluating an Airworthiness Directives Management Process; Volume 3,
Chapter 59, Section 1 (June 1, 2011); and
o Risk Management Process, Volume 10, Chapter 3, Section 1
(January 10, 2011).
 FAA Order 8110.103A, Alternative Method of Compliance53
(September 28, 2010); (http://rgl.faa.gov);
 FAA Order 8100.15A, Organization Designation Authorization Procedures
(June 10, 2011); (http://rgl.faa.gov);
 FAA Order 8110.37E, Designated Engineering Representative (DER) Handbook
(March 30, 2011); (http://rgl.faa.gov);
 FAA Airworthiness Directives Manual, FAA–IR–M–8040.1C (May 17, 2010);
(http://rgl.faa.gov);
 AC 39–9, Airworthiness Directives Management Process (June 1, 2011);
(http://rgl.faa.gov);
 Draft AC 20–xxx, Design Approval Holder Best Practices with Regards to
Airworthiness Directives (June 13, 2011); (http://rgl.faa.gov);
 Notice N8100.112, Placing Service Information in the Federal Docket
Management System (September 28, 2010); (http://rgl.faa.gov);
53
In addition, the FAA issued FAA Order 8110.103A, CHG 1 on June 30, 2011.
Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page I–1

 ATA Specification 111, Airworthiness Concern Coordination Process
(October 2011); (http://www.airlines.org); and
 ATA iSpec 2200, Information Standards for Aviation Maintenance (May 2011);
(http://www.airlines.org).
Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page I–2

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SUBJ: Airworthiness Directive Implementation Aviation Rulemaking Conunit1ee

5. Organization and Administration of the Airworthiness Directive Implementation ARC. We

(1) Appoints members or organizations to the committee, at her sole discretion;

b. The co-chailjJOrsons will:

8. Committee Procedures and Tasks.

(3) Reviewing, approving, and implementing the program plan.

Ali Bahrami Terry McVenes

Constance Arnold Robert Bernicchi

William M. Cavitt Steven W. Douglas

Rolf Greiner John Kotnjek

Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page ii

Sarah MacLeod Antonio Victorazzo

Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page iii

LETTER FROM AD ARC CO-CHAIRS ............................................................................. viii

EXECUTIVE SUMMARY ...................................................................................................... ix

Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page v

5.0 CONCLUSION .............................................................................................................. 69

APPENDIX A—SERVICE INFORMATION WORKING GROUP ......................................... A–1

Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page vi

APPENDIX G—AD ARC CHARTER .............................................................................. G–1

APPENDIX H—PROPOSED FAA LEGAL INTERPRETATION ......................................... H–1

APPENDIX I—LIST OF AD ARC DELIVERABLES ........................................................... I–1

Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page vii

August 20, 2011

Ms. Margaret Gilligan

Dear Associate Administrator Gilligan,

Terry McVenes, Director Ali Bahrami, Manager

Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page viii

The AD ARC developed new industry guidance to improve AD management processes

Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page ix

Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page x

AD ARC Implementation Action Deliverables

Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page xi

Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page xii

In its final report to the Secretary of Transportation6, the IRT presented

1.2 AD ARC CHARTER

Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page 1

A copy of the charter is contained in appendix G to this report.

1.3 AD ARC COMPOSITION AND ACTIVITY

Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page 2

1.3.2 Program Plan and Implementation Schedule

1.4 SCOPE OF THIS REPORT

Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page 3

Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page 4

Specifically, the AD ARC actions initiated—

Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page 5

Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page 6

―Review §§ 39.7 and 39.9, and, if necessary, revise those sections to

The primary issues the FPWG discussed are—

A copy of AFS–300’s request is contained in appendix H to this report. In addition, see

In addition to AFS–300’s interpretation request, the Aeronautical Repair Station

Request for Extension of Comment Period

Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page 7

―Carried to its extreme, the unique status of AD configuration

As discussed previously, the AD ARC’s improvements to processes underlying the broad

Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page 8

The proposed FAA legal interpretation explains that amendment 39–106

Airworthiness Directive Implementation Aviation Rulemaking Committee Report Page 9

2.3.1 Maintenance in ADs

2.3.2 Later Approved Parts

Design Approval Holder (DAH) design changes approved after the