All aircraft operators and maintenance providers.
The CAA has recently been requested to clarify whether the Inspection Planning Latitude in Rule 91.611 can be utilised for repetitive Airworthiness Limitation (AWL) inspections which are specified in the aircraft Instructions for Continuing Airworthiness (ICA).
Airworthiness Limitations applicable to an aircraft, or a component are approved by the responsible National Aviation Authority (NAA), also known as the State of Design (SoD).
Airworthiness Limitations, including repetitive AWL inspections are mandatory, and can only be changed by the responsible NAA of the SoD in consultation with the aircraft manufacturer, or the component manufacturer.
Rule 91.603(b) mandates compliance with the Airworthiness Limitations specified in the ICA for an aircraft.
If the manufacturer provides an inspection planning latitude, or a tolerance in the AWL section of their ICA, then operators are entitled to utilise this. It is vital that all requirements associated with this tolerance are complied with, and that the extended latitude is not exceeded.
If the manufacturer does not provide an Inspection Planning Latitude, or tolerance in the Airworthiness Limitations section of their ICA, no latitude can be applied.
It is not appropriate for an operator to apply the Inspection Planning Latitude in Rule 91.611 to an Airworthiness Limitation mandated by Rule 91.603(b), and
It is not appropriate for an operator to utilise the Deferred Compliance provision in Rule 39.55 to an Airworthiness Limitation mandated by Rule 91.603(b), and
It is not appropriate for an operator to utilise the Deferred Compliance provision in Rule 39.55 to an Airworthiness Limitation which may be subject to an Airworthiness Directive.
Operators and maintainers are advised to identify all inspections in the applicable ICA which are subject to an Airworthiness Limitation and must ensure that a process is in place to prevent inadvertent application of an inspection planning latitude to an AWL.
