Last April the Aeronautical Repair Station Association (ARSA) brought together 11 companies to develop and refine a draft policy that the association had made public the previous month. The companies included some of the largest aerospace product and component manufacturers and independent maintenance providers in the world, including Delta Air Lines, Lufthansa Technik, Nordam Group and Pratt & Whitney.
Despite the group’s diversity, for the most part the members were able to agree on solutions to address a long-standing problem: the availability of maintenance manuals, particularly for components installed on an aircraft. The group submitted a Joint Industry Policy on Instructions for Continued Airworthiness to the FAA.
The FAA has always required manufacturers of aircraft products, such as the airframe, engines and propellers, to prepare maintenance manuals and make them available to owners and those who repair and overhaul the products.
According to FAR 21.50(b), “[T]he holder of a design approval, including either the type certificate or supplemental type certificate for an aircraft, aircraft engine or propeller...shall furnish at least one set of complete instructions for continued airworthiness...to the owner of each type of aircraft, aircraft engine or propeller upon its delivery, or upon issuance of the first standard airworthiness certificate for the affected aircraft, whichever occurs later, and thereafter make those instructions available to any other person required by this chapter to comply with any of the terms of these instructions. In addition, changes to the instructions for continued airworthiness shall be made available to any person required by this chapter to comply with any of those instructions.”
According to Marshall Filler, ARSA’s managing director and general counsel, the problem is that the FAA has not required that aircraft component maintenance manuals (CMMs) be made available under the same terms. “The aircraft manufacturer has been required only to provide ‘remove and replace’ instructions and procedures for limited servicing of the component while it is installed on the aircraft,” he told AIN. “However, most component maintenance is performed off the aircraft by highly specialized facilities that are required to have the CMMs and follow them when they perform work on the affected component.”
Access to Component Maintenance Manuals
It is ARSA’s position that CMMs are essential to the continued airworthiness of the product and therefore manufacturers of aircraft and their components should ensure that CMMs are made available to maintenance personnel in the same manner as the manuals for the aircraft, engines and propellers.
Filler said there is a breakdown in communication within the FAA between the Aircraft Certification Branch, which sets policy about who must be given the documents, and the Flight Standards Branch, which insists that repair stations have current manuals in their possession before they can work on a component. “The problem is that Flight Standards isn’t in charge of who has the responsibility to create and distribute the manuals. That is left to Aircraft Certification.”
As it stands now, buyers of new aircraft don’t have any problem getting the manuals because they operate the aircraft, but the manufacturer is not required to provide them to repair stations, FBO maintenance facilities or even an operator who has purchased a used aircraft.
Over the past few years there has been a paradigm shift with respect to OEMs and maintenance. Not long ago very few OEMs had any interest in doing maintenance, but now maintenance has become a profit center for them. It appears the real issue is one of competition. The way the independent maintenance facilities see it, the decision by many OEMs to refuse to provide them with manuals at best smacks of trying to eliminate competition. The joint industry policy would require most FAA design approval holders, including manufacturers of FAA-approved components, to prepare and make available to the public, at a fair and reasonable price, basic, off-aircraft component maintenance and overhaul information.
“We don’t disagree that OEMs have a right to be in the maintenance business,” Filler emphasized, “and we certainly appreciate that nobody in the industry wants to give away proprietary information. All we want is basic information on how to do common repairs and how to inspect and overhaul the component. That’s what we believe to be essential for continued airworthiness.”
One supervisory-level individual at an MRO related his anger over a Hamilton/ Sundstrand APU manual for a Hawker that was quoted at more than $20,000. “In another instance we had an OEM that wouldn’t sell us the component maintenance manual at any price, yet would sell it to an aircraft operator,” he said.
Another MRO manager recalled trying to obtain a Hamilton/Sundstrand APU manual for the Learjet 60 series. “It took a lot of effort to track down the publication. When we did, we were horrified to learn it sells for $13,400! You have to be in possession of the manual to do any work at all, but $13,400 just to be able to change the oil and filter?” he asked. He pointed out that the APU component maintenance manual costs more than all of the technical publications for the entire aircraft combined.
A representative from an OEM that operates its own MRO recently lamented that the company was having a problem. It is expanding its maintenance business to a new line of aircraft and having trouble getting some component maintenance manuals for competitors’ products. It seems some manuals were unavailable while others were grossly overpriced.