Considering the Need for an Aircraft Maintenance Component Replacement Program
Sofema Online (SOL) www.sofemaonline.com considers the elements involved in an effective component replacement program.
Introduction
Effective management of aircraft components is an essential aspect of aircraft maintenance programs and plays a critical role in ensuring the safety, reliability, and efficiency of aircraft operations. Proper management of aircraft components helps to prevent unscheduled maintenance, reduce operational downtime, and ensure that aircraft systems and equipment are always in top working condition.
An important aspect of component management is the use of predictive maintenance techniques. This involves using data from various sources, such as performance monitoring and historical maintenance records, to identify potential issues and predict when maintenance may be needed. This helps to prevent unscheduled downtime and improve overall efficiency.
By implementing robust and well-designed maintenance programs, organizations can ensure that aircraft components are always in top working condition and that aircraft are able to operate safely and effectively.
Related to Considerations Related to Mandatory Obligations
» Service Bulletins may or may not be approved by regulatory authorities. (connected with an AD for example)
» It is possible for a Service Bulletin to be adopted and made mandatory by the regulator of the state of the manufacturer. (typically in conjunction with an AD)
» Conversely, it is also possible for a Service Bulletin to be written in support of a requirement generated through an AD
From a regulatory point of view, the SB may not be required. However, this is only one part of the story. SBs may also be driven by Lease Obligations or by Organizational decisions.
» Whilst the intention of the SB provider is to raise the standard of safety, the operator may view the cost of the bulletin as not effective for the particular aircraft, engine or component.
» For the Operator to automatically comply with service bulletins may result in increased maintenance costs. For this reason, it is normal for the Operator to implement a Service Bulletin Analysis process.
Note: Even Free of Charge Service Bulletins may not be free!
A survey of Service Bulletin's 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.
A template may be used for this purpose which will consider all the relevant criteria which are applicable including the remaining length of the lease, the various obligations, as well as benefits to both safety & reliability. A cost-benefit analysis will allow the operator to compare the cost of embodying the aircraft maintenance service bulletin (compliance) in light of the perceived benefits.
With this information, the appropriate decision should become more obvious.
EASA Certification Memorandum CM-21.A-J-001 has been issued to provide advice and guidance on this subject.
» The case of an SB for which an AD has been issued, irrespective of whether it is designated by the TC/STC holder as ‘mandatory’, ‘alert’ or ‘highly recommended’, is clear: these are part of the Mandatory Continuing Airworthiness Instructions and must be applied in all cases.
» The case of SBs designated as ‘mandatory’, ‘alert’ or ‘highly recommended’ by the TC/STC holder for which no AD has been issued is more complex and the following cases should be considered:
» The TC/STC holder subsequently includes such SB (e.g. repetitive inspection instructions) in the manufacturer maintenance programme (Maintenance Review Board Report (MRBR) or Manufacturer Recommended Programme) for the aircraft concerned.
o In this case, the SB under consideration will need to be included in the aircraft maintenance programme as defined in Commission Regulation (EU) No 1321/2014, M.A.302(d) and (g) (see also AMC M.A.302(d)) to ensure compliance with instructions for continuing airworthiness issued by the TC/STC holder.
In the event that the TC/STC holder does not include SBs in the manufacturer maintenance programme (MRBR or Manufacturer Recommended Programme) for the aircraft concerned. The final decision to apply such SB lies with the owner/operator or contracted CAMO, as M.A.302(g) does not apply.
For all non-mandatory modifications and/or inspections, including SBs classified by the TC/STC holder as ‘mandatory’, ‘alert’ or ‘highly recommended’ and not covered by a corresponding AD, for all large aircraft, or aircraft used in commercial air transport, an embodiment policy is to be established, as required by M.A.301(7.).
That policy should then result in a substantiated (and recorded) operator’s decision for each SB to apply it, or not!
The Role of Vendor Service Bulletins (VSB)
VSBs are Issued by equipment or component manufacturers, they are typically driven by reliability-related data sets, as well as other in-service issues which are experienced by operators.
Whilst a full awareness of the reasons for VSBs should be understood by the CAMO, VSBs are usually considered when a component is removed as defective.
Note: Like SBs, VSBs may also be the subject of Airworthiness Directive Actions. (however, it is not possible for a standalone VSB to be described as Mandatory (Alert – Yes)
VSB – Soft (Vendor Soft Service Bulletins (VSB))
Some VSBs are known as soft bulletins – For example, Soft Bulletins may be placed against an engine but not performed until the engine is removed from the wing which could be some years
Vendor Service Bulletins are issued by equipment or component manufacturers, typically driven by reliability in service issues which are experienced by operators.
Just as with Service Bulletins, VSB may be the subject of Airworthiness Directive Actions.
Whilst a full awareness of the reasons for Vendor Service Bulletins should be understood by the Continuing Airworthiness Management Organization, Typically VSBs are considered when a component is removed as defective.
Next Steps
Please see www.sassofia.com & www.sofemaonline.com for multiple courses compliant with EASA Part CAMO objectives. Email team@sassofia.com for any questions or further guidance.
