As mechanics, we are required to have “current” maintenance manuals and inspection programs to perform work on a client’s aircraft. It’s reasonable to think this means we need to posses and perform our tasks with reference to the relevant documents as subsequently revised. But, according to several FAA legal interpretations, that isn’t true!
With respect to maintenance, the FAA defines “current” to mean: “at the time the aircraft was manufactured, or in the case of inspections, when the inspection program was adopted by the owner or operator.” There have been several legal interpretations by the FAA that address or reference this definition of “current,” but one in particular is important.
In a May 2015 legal interpretation regarding an Airworthiness Limitations Section (ALS) being added to the Cessna 210 Maintenance Manual, the FAA states:
Once an aircraft is produced under a type certificate, the type design of that particular aircraft is fixed in time, absent an FAA requirement to make a retroactive change, or an owner’s voluntary change, if it is approved under a method acceptable to the FAA.
To the extent “current” maintenance manual contains the after-added ALS; using it would be acceptable, but not mandatory, as the previous revision without the new ALS would still be acceptable to the FAA – again absent an AD or other rule that would make the new ALS retroactive and mandatory.
So when a 1903 Wright Flyer comes in for an inspection, unless there’s been an AD mandating the use of a newer maintenance manual or inspection program, go ahead and use the one the bicycle shop used in 1903… It’s “current.”
Similar information and tips to help ensure your maintenance is conducted safely and in accordance with the regulations is incorporated into the current (dictionary meaning) revisions of the Gleim IA Renewal Course. Our goal is to make IA renewal training applicable to the real world while reminding you of the knowledge needed for effective aircraft inspections. Check future Gleim blog posts for information about updates to the IA Renewal Course and other maintenance related articles.
Written by Clay Gamber, Gleim Aviation Editor