AD records - the sky is the limit?

Flight Training Europe SL • 17 April 2020

in community General Aviation

1 likes

With the introduction of part ML in the current CAW regulation, a peculiar clarification was made in regards to the Aircraft continuing-airworthiness record system, specifically AMC ML.A.305 c) where it is stated that "if the AD is generally applicable to the aircraft or component type but is not applicable to the particular aircraft, engine, propeller or component, then this should be identified as well as the reason why it is not applicable".

A literal interpretation of this AMC (and we all know how the NAAs love AMCs and literal interpretations) leads to keeping a record of ALL ADs applicable per TYPE of products (Aircraft, engines and propellers).

As an example, and considering someone who owns a Piper PA28-161 aircraft, he/she is required to keep a record of ADs not only for this model but also for all other PA28 including but not limited to PA28S, PA28R and PA28RT. As for someone who owns a Diamond DA42, they will required to keep AD records for the DA62 as well because it is in the same TYPE CERTIFICATE.

A couple of questions for EASA here then:

1. Couldn't we just keep this to MODEL for products? Why Type?

2. What is the TYPE of a component (considering their approval under Subpart O)? Again, whilst MODEL is a more ambiguous term here, I would definitely recommend that word (e.g. Garmin G1000, or Bendix KT76).

Having said that, I do appreciate the clarification and the effort being made here. I just believe the word TYPE is poorly chosen and EASA should clarify what it means by it (unless it is literal).

Hoping to hear from you soon,

Stay safe!

Comments (3)

zoran buckovic • 4 years ago

Very correct.

Cristina ANGULO • 4 years ago

Dear Flight Training Europe Jerez,

In AMC1 ML.A.305 c) it is stated that "if the AD is generally applicable to the aircraft or component type but is not applicable to the particular aircraft, engine, propeller or component, then this should be identified as well as the reason why it is not applicable". The EASA’s interpretation is that ‘generally applicable to the aircraft […] type’ should be understood as an AD applicable to all models that exist for the aircraft type. Therefore, if an AD applies only to certain models of a type, it is not ‘generally applicable to the aircraft type’.

The same AMC sentences already existed in Part M and its continuation in Part ML should not lead to a new interpretation.

Best regards,
Jannes & Cristina.

Flight Training Europe SL • 4 years ago

Dear Cristina & Jannes,
Thank you so much for taking the time to reply to this post. I really appreciate the help and support EASA is showing the community.
It is clear then, from EASA's interpretation, that if the AD does not specifically include "my" MODEL (and considering it is not a blanket AD for the type or configuration) then that record is not required to be kept as ALL models are not listed. This, I believe, is the same as using the word MODEL, which would leave less room for interpretation.
What about component TYPE? Could you please clarify on that?
It is indeed true that the requirement was there from Part M, but it was changed with the introduction of Part ML to include the record of "why it is no applicable" (and no need to record superseded ADs).

Again, thank you so much for your support and dedication, I hope you are keeping safe and that all the EASA family is in good health.

Kind regards,
Daniel

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