When should I revise my Aircraft Maintenance Programme (AMP)?
In accordance with M.A.302(g), the Aircraft Maintenance Programme (AMP) shall be subject to ‘periodic reviews’ and amended accordingly when necessary.
This means that the owner/operator/CAMO should review at a regular interval:
- new/modified maintenance instructions by the TC holder,
- modifications and repairs embodied in the particular a/c, which may require compliance to additional maintenance instructions (by Design Approval Holder),
- in-service experience collected for the particular a/c or for the fleet and
- changes in the type and specificity of operations
Such a review allows to determine if an AMP revision is necessary to still comply with the obligations of M.A.302(d)(ii)/(iii) and ensure that the AMP continues to be valid in light of the operating experience. As a minimum, point (3) of AMC M.A.302 states it should be at least a 1-year review interval (annual review).
However, this should not prevent amending the AMP outside of this formal periodic review, when a specific need arises. This may depend for example on in-service experience (e.g. adverse trend), nature of instruction revisions (e.g. significant reduction of TBO (time between overhaul)), the extent of instruction revisions (amount of affected tasks) as well as source of instruction revisions (e.g. MRBR, ALS, etc.)
When a revision of the ALS (Airworthiness Limitation Section) introduces a new or more restrictive task, EASA has the policy to issue an AD (Airworthiness Directive). Such an AD would typically mandate on one side the revised task accomplishment and on the other side the revision of the AMP itself, together with a compliance time for these two actions.
However, in accordance with point (3) of AMC M.A.302, EASA recommends to review the AMP as soon as possible in this case to avoid a disconnection between accomplished maintenance task(s) and maintenance task(s) listed in the AMP.
If the aircraft’s continuing airworthiness is being managed by a CAMO, the CAME (Continuing Airworthiness Management Exposition) should describe the AMP revision policy (including ‘periodic review’) under point 1.2 [Appendix V to AMC M.A.704].
Remark: In the case where the source documents are amended without having an effect on the AMP content, it is acceptable to use an indirect approval procedure (if granted by the competent authority in accordance with M.A.302(c)) to amend the relevant source document references in the AMP.