Considerations Related to the need for a Baseline Corrosion Prevention and Control Programme (CPCP)

Sofema Online (SOL) www.sofemaonline.com reviews the development of CPCP from Standalone to incorporation within the MRB process

Introduction “Corrosion Prevention and Control Programme” (CPCP)

This means a document reflecting a systematic approach to prevent and control corrosion in an aeroplane’s primary structure, consisting of basic corrosion tasks, including inspections, areas subject to those tasks, defined corrosion levels and compliance times (implementation thresholds and repeat intervals).

FAA Requirements

>> After the 1988 accident, the NTSB recommended that the FAA develop a model for a comprehensive CPCP that would be included in each operator’s approved maintenance program.
>> The aviation industry and CAAs formed the Airworthiness Assurance Task Force (AATF) to address issues related to ageing aircraft. Among the issues addressed by the AATF was the need to develop baseline CPCPs.
>> The AATF identified 11 specific aeroplane models (the Airbus A-300; British Aerospace BAC 1-11; Boeing 707/720, 727, 737, and 747; Fokker F-28; Lockheed L-1011; and McDonnell Douglas DC-8, DC-9, and DC-10) based on findings that the initiation and spreading of corrosion in the metallic structures of those aeroplanes created an “unsafe condition.”

o As a result, the FAA issued ADs that mandated specific CPCPs for those 11 airplane models.

Note: The AATF later was renamed the Airworthiness Assurance Working Group (AAWG) and was tasked by an FAA Aviation Rulemaking Advisory Committee to develop recommendations on whether new or revised requirements and compliance methods for CPCPs should be instituted and made mandatory

The AAWG recommended in their report to the FAA that the CPCP task be considered closed.

>> CPCPs were being proposed or adopted for all of the affected aircraft through the AD process, and the FAA was proposing a regulation for commercially operated air transport category aircraft that would require CPCPs to be approved and incorporated into each aircraft type’s maintenance program.
>> The AAWG endorsed this proposed rulemaking effort because it would provide the FAA with explicit regulatory authority to mandate comprehensive CPCPs.
>> The FAA issued a Notice of Proposed Rulemaking (NPRM) in October 2002 with a requirement to include FAA-approved CPCPs in operators’ maintenance or inspection programs.

o However, the proposal was withdrawn in 2004 because the FAA’s safety objectives were met through the incorporation of CPCPs in maintenance programs through the MSG-3 process for airplanes for which the FAA did not mandate CPCPs by AD; there was no need for further regulation.

EASA Requirements:

A baseline CPCP is established by the type certificate holder, which can be adapted by operators to create a CPCP in their maintenance programme specific to their operations;

a) A holder of a type-certificate (TC) or a restricted TC for a turbine-powered large aeroplane certified on or after 1 January 1958, for which the application for TC was submitted before 1 January 2019, shall establish a baseline corrosion prevention and control programme (CPCP).
(b) Unless the baseline CPCP referred to in paragraph (a) has already been approved by the Agency in accordance with point 21.A.3B(c)(1) of Annex 1 to Regulation (EU) No 748/2012 or in a maintenance review board report (MRBR) approved by the Agency, the holder of a type-certificate (TC) or a restricted TC shall submit the CPCP to the Agency before 26 February 2023, for approval.
(c) An applicant for a TC or restricted TC as referred to in letter (c) of Article 1 paragraph 2, for a turbine-powered large aeroplane shall establish a baseline corrosion prevention and control programme (CPCP) before the TC is issued.

Compliance with point 26.304 of Part-26 is demonstrated by complying with CS 25.571 Amendment 19 or subsequent amendment, or with points (a) or (b) of this CS:

(a) A baseline CPCP is established according to AMC 20-20A Paragraph 9 or equivalent means, it includes a statement that requires the operator to control corrosion to Level 1 or better and is submitted to EASA for approval.
(b) A baseline CPCP already exists for the type that is either approved by EASA through the maintenance review board (MRB) and industry steering committee (ISC) using existing procedures for EASA maintenance review board report (MRBR) approval or through an existing EASA AD.

Next Steps

Please see the following course (currently available as classroom or webinar training): FAA & EASA Corrosion Protection and Control Program – 2 Days

For additional information please see www.sassofia.com or www.sofemaonline.com.

Please email team@sassofia.com for any questions or comments