FAQ n.48248

How is it possible to escalate AMP task intervals?

Answer

General:
Some general expectations for escalation initiatives are described in the following paragraph:
a) It should be ensured that the AMP continues to be valid in light of the operating experience [M.A.302(g) – see FAQ n.47406].
b) It should form part of the analysis of the effectiveness of the AMP (if required by M.A.301(4)),
c) The AMP should include a procedure to manage the escalation of established intervals [AMC M.A.302 point (4) and point (2) of AMC M.B.301(c)].
    Supported by
      - formal reliability programme if required by M.A.302(f) or voluntarily implemented [AMC M.A.302(d) point (6)] or
      - collection and analysis of in-service experience.
 ‘Appendix I to AMC M.A.302 and AMC M.B.301(b)’ provides detailed guidelines for the integration of this information into the AMP.
d) If there is a CAMO involved, those points also have to be emphasised within the CAME, as specified in Appendix V to AMC M.A.704.

Two different cases:
The escalation of AMP task intervals falls into the alternative instructions proposed by the owner/ CAMO [M.A.302(d) point (iii)] and distinguishes in the following cases:
Case 1:
Escalation of safety-related task intervals, which consist of all mandatory tasks (Airworthiness Limitation Section) as well as certain non-mandatory tasks issued by the DAH (Design Approval Holder) such as various MRBR (Maintenance Review Board Report) tasks [see note below], tasks related to emergency equipment, critical components…
Case 2:
Escalation of non-safety-related task (e.g. non-safety related MRBR task or a task recommended by a Service Letter) intervals

Note:
In cases, where the aircraft type has been subjected to the MRB process, the following MRBR tasks should be considered safety-related:
- Failure Effect Category (FEC) ‘5’ (evident safety) and ‘8’ (hidden safety) tasks (systems and powerplant)
- SSI (Structural Significant Item) tasks
- L/HIRF (Lightning / High Intensity Radiated Field) tasks (as applicable)
- Stand-alone EWIS tasks (EZAP procedure)

Escalation approval:
The approval of a task escalations is addressed separately for each case:

Regarding case 1:
1.1 Escalation of mandatory tasks represents a change of the initial type design and therefore must be discussed and agreed between the DAH and the Agency*.
1.2 The AMP revision proposal and the information used to substantiate the escalation of non-mandatory tasks [AMC M.B.301(d)] have to be evaluated by the competent authority [AMC M.B.301(b) point (2)]. Following a positive evaluation, a direct approval of the AMP revision will be issued by the competent authority, as stated in M.A.302(d) point (iii).

Regarding case 2:
An indirect approval of the AMP through a CAMO is possible and described in more detail in FAQ n.19061.

* Exception may exist under certain condition for Two Star CMR (Certification Maintenance Requirement) (see AMC 25-19).
 

Remarks:
- In all cases, task de-escalation may need to be considered based on the supporting data [AMC M.A.302(f) point (4)].
- Escalation should not be confused with ‘permitted variations’ to AMP intervals, which applies to a unique aircraft for a unique occasion [‘Appendix I to AMC M.A.302 and AMC M.B.301(b)’ point (4)].

Last updated: 
22/08/2018

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