Component Service Bulletins: Exploring the case to embody or not to embody?
The owner of the Type Certificate for the Aircraft, Engine or Supplemental Type Certificate (STC) has an obligation to ensure the continuity of the continuing airworthiness of the product.
The component Original Equipment Manufacturer (OEM) with a Technical Standing Order (TSO) or European Technical Standing Order (ETSO).
The Part manufacturer through Parts Manufacturing Approval (PMA) or European Parts Approval (EPA) also has the obligation to maintain continuing airworthiness oversight.
The service bulletin is the delivery vehicle by which the “owner” of the product maintains the integrity of the continuing airworthiness of the component, however not all suggested actions are mandatory, some may be related to reliability still others related to cosmetic improvements.
Operators and Owners have an entitlement to Service Bulletins which is not the case for Maintenance Repair Organisations (MRO’s).
The hierarchy of information starts with Alert Service Bulletins (ASB) which almost always contains mandatory information, followed by Service Bulletins (SB) – note there is an obligation driven by EASA Part M for the CAMO of the Operator to demonstrate a process of analysis. At the lowest levels we have Service Letters or Service Information Letters and Service or Maintenance Instructions.
A service bulletin typically contains information from the author regarding actions which it believes should be considered for embodiment. It may contain recommended compliance with which there is an obligation of the Operator to comply.
Whilst the manufacturer may identify a SB as mandatory compliance is not actually mandated by either EASA or the FAA unless such a bulletin is linked to an Airworthiness Directive AD in which case it is of courses mandatory.
Whilst we may now understand that it is not mandatory we should also understand that one of the reasons the manufacturer issues an SB is because either it is protecting its own reputation or it has determined that compliance will lead to a safer product.
The opportunity therefore presents for the operators CAMO to analyse investigate fully and to embody component SB’s for the right reasons, this approach offers significant cost savings whilst recognising that of course if the SB is related to Safety it will be embodied without compromise.
Even Free of Charge Service Bulletins may not be free! Research has indicated that the actual cost of embodying a service bulletin (This will typically translate into higher maintenance costs). A survey of Service Bulletin true costs showed that the actual cost of embodiment was between 7 to 13 times the basic cost of the Service Bulletin.
Therefore it makes sound financial sense to review SB’s not just for Safety Benefits, but for economic benefits and to make a balanced decision to embody.
Sofema Аviation Services offers a range of Regulatory and Vocational training to comply with the requirements of EASA. Please see www.sassofia.com or our online training portal www.sofemaonline.com or email us at office@sassofia.com or online@sassofia.com
