Part-66 Module 10 study materials
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The AD the Due List Missed

Part-66 Module 10 · Put your knowledge to work in context.

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The AD the Due List Missed

Atlantic CAMO manages eight ATR 72-500s and four A320-214s under Part-CAMO. In late February EASA issues AD 2025-0042, effective 1 March, applying to the ATR 72-500 main landing gear. It requires: 'Within 600 flight hours or 12 months, whichever occurs first, from the effective date of this AD, and thereafter at intervals not exceeding 600 flight hours, accomplish a detailed inspection of the MLG pintle pins in accordance with the SB. Note: for aircraft on which the MLG has been overhauled in accordance with SB ATR-72-32-1050, the initial inspection is not required.' The operator's approved maintenance programme permits a 10 % tolerance on scheduled tasks. Msn 812 reached 560 flight hours since its last MLG overhaul and is three weeks from a C-check; a planner marks it 'within tolerance'. Msn 795, in service, is found to be 604 flight hours past the AD threshold.

1. Msn 812's planner wants to use the maintenance programme's 10 % tolerance to carry the AD inspection into the C-check. Is that permissible? Set out how the CAMO should control AD compliance times.

Read the worked answer

No. The 10 % tolerance belongs to the maintenance programme tasks; it does not extend an AD compliance time.

  • ADs are mandatory continuing-airworthiness requirements. The aircraft may not be operated unless the AD is complied with within its stated limits. A tolerance in the approved maintenance programme applies to tasks generated by the programme, not to a limit imposed by an AD.
  • An extension is possible only where the AD itself provides for it, or where an alternative method/timing has been approved by the authority that issued the AD. Otherwise the limit stands.

How the CAMO should control it:

  1. Incorporate the AD into the aircraft's maintenance programme and due-list at the moment of receipt, with a distinct 'AD' task identifier so it can never be merged into a routine check tolerance.
  2. Establish per aircraft the datum the AD uses - flight hours accumulated from the effective date, or calendar months - and track it against the actual FH count, not the projected utilisation.
  3. Plan the accomplishment with margin: an inspection forecast to fall due during a C-check is scheduled at the C-check only if the due point is genuinely later.
  4. Where an AD-specified interval and a programme task coincide, the AD limit governs the earlier of the two.

On these facts, msn 812 is planned for inspection before it reaches 600 FH from the effective date, or before 12 months - whichever comes first - regardless of the C-check date.

2. Msn 795 is discovered at 604 flight hours past the threshold while in service. What must the CAMO do?

Read the worked answer

The aircraft is in non-compliance and must be grounded until the AD inspection is accomplished.

Sequence:

  1. Stop operations - instruct the operator that msn 795 is not to fly; the CAMO cannot authorise flight with an AD outstanding.
  2. Establish the facts - how many FH beyond the limit, over what period, on which flights; whether the due point was miscalculated (wrong FH datum, unincorporated AD, planning error) or simply missed.
  3. Accomplish the AD at the earliest opportunity and certify it; if the inspection reveals defects, handle them to the approved data before release.
  4. Assess airworthiness of the flights already made - was there an unsafe condition during those flights? That assessment drives the urgency and the reporting.
  5. Report. An AD exceedance is an airworthiness-relevant event: raise it through the mandatory/occurrence-reporting system and inform the competent authority, the operator, and the owner/lessor if contractually required. Do not wait for the investigation to be complete before notifying.
  6. Root cause and corrective action - audit the AD-incorporation process across the whole fleet, verify the other eleven aircraft, correct the due-list logic, retrain, and record the corrective action in the CAMO's quality system.

The exceedance is not closed by doing the inspection; it is closed when the organisation can show why it will not recur.

3. Msn 812's MLG was overhauled to revision 2 of SB ATR-72-32-1050, while the AD note refers to the SB without stating a revision, and revision 3 adds a pintle-pin check. Can the CAMO take credit for the overhaul and skip the initial inspection?

Read the worked answer

Not on that basis. The note has to be applied as written and evidenced.

  • The AD note exempts the initial inspection for aircraft whose MLG has been overhauled in accordance with the SB, because the overhaul is deemed to embody the required work. Whether rev 2 does embody it depends on what rev 3 added: if rev 3 introduces a pintle-pin check that rev 2 did not include, an overhaul to rev 2 has not accomplished equivalent work.
  • The CAMO's options, in order of preference: (a) accomplish the AD inspection as written - the simplest and always defensible route; or (b) obtain written confirmation from the TC holder, or from the authority that issued the AD, that overhaul to rev 2 satisfies the intent, supported by the workshop findings from the overhaul, and record that determination on the compliance file before relying on it.

A CAMO engineer's own opinion that 'rev 2 is close enough' is not a basis for non-compliance. Credit for previous work must be evidence-based, documented, and traceable to the AD's own wording.