Contributed by Pete Mills, Chief Inspector and Mike Mertens, Regulatory Compliance Manager. Written in conjunction with the Lincoln, Neb. Flight Standards District Office (FSDO).
Duncan Aviation works closely with the FAA and operators to ensure RVSM compliance.
Understanding what regulatory requirements must be met for a service provider to issue an approval for return to service for Reduced Vertical Separation Minimums (RVSM) maintenance and inspections can be very confusing. Boiling down the requirements is best done by referring back to Federal Aviation Administration (FAA) regulations and supporting documentation. The primary document providing this guidance is FAA Order 8100.9, Volume 4, Chapter 10, Paragraph 4-1235.
The RVSM Maintenance Program Requirements
Only an FAA approved RVSM maintenance program will allow a service provider to sign off on RVSM services. FAA regulations require that operators follow “…an approved RVSM maintenance program” to operate in RVSM airspace, as per an Part 91 operator’s Letter of Authorization (LOA), Part 91K operator’s Management Specifications (MSpecs), or Part 121 – 135 operator’s Operations Specifications (Ops Specs)
The Differences Between an LOA, MSpecs & Ops Specs
The LOA, MSpecs and Ops Specs are often confused with each other. The difference lies in how the aircraft is operated. This is identified in FAA Order 8900.1, Volume 3, Chapter 18, Paragraph 3-736.
- Part 91 RVSM-certified operators will have an LOA stating they may operate in RVSM airspace as long as they follow "...an approved RVSM maintenance program."
- Part 91K (Fractional operator) RVSM-certified operators will have MSpecs stating they may operate in RVSM airspace as long as they follow "...an approved RVSM maintenance program."
- Part 121 - 135 RVSM-certified operators will have Ops Specs issued in place of an LOA or MSpecs. The Ops Specs require an operator to follow an approved RVSM maintenance program.
What the LOA, MSpecs or Ops Specs Mean
One of the more common points of confusion is how the LOA, MSpecs or Ops Specs are involved in an RVSM maintenance program. All of these documents outline the regulatory requirements for the operator’s RVSM approval, and verifies the need for an approved RVSM maintenance program. If there is ever a question about whether or not an approved RVSM maintenance program is required to issue approval for return to service for RVSM maintenance or inspections, refer to the operator’s LOA, MSpecs or Ops Specs, as appropriate.
An ICA, AFM, MM, SB or AAIP Do Not Replace the Approved Maintenance Program Requirement
There is no documentation that will waive the requirement to follow an approved RVSM maintenance program. Instructions for Continued Airworthiness (ICA), an FAA approved Aircraft Flight Manual (AFM), maintenance manual (MM) instructions, service bulletins (SB) or an Approved Aircraft Inspection Program (AAIP) are not an approved RVSM maintenance program. Nor is the LOA, MSpecs or Op Specs a substitute for an approved RVSM maintenance program. The ICA, AFM, MM, SB and AAIP information may be a part of or contained in, the FAA Approved RVSM program, but does not replace it.
An FAA Approved RVSM Maintenance Program may be a stand alone document or it may be incorporated in some other document such as a General Maintenance Manual (GMM), International Operations Manual (IOM), or Continuous Airworthiness Maintenance Program (CAMP). No matter where it is located, there still must be an indication that the RVSM maintenance program has been FAA Approved. This approval will be indicated by:
- the Approval date,
- the word Approved,
- the approving FSDO Inspector signature (pen and ink or electronic), and
- the approving FSDO’s office designator being placed on the document.
Duncan Aviation provides complete business aircraft maintenance, repair and overhaul (MRO) services and we work closely with the FAA to ensure RVSM compliance. RVSM maintenance and inspections are supported by our full-service facilities and our network of avionics shops located across the United States
Pete Mills is a Chief Inspector at Duncan Aviation’s Battle Creek, Mich. facility, specializing in general aviation maintenance. He began working in aviation in 1976. Mike Mertens is the Regulatory Compliance Manager at Duncan Aviation’s Lincoln, Neb. facility, specializing in general aviation maintenance and alteration regulation compliance. He began working in aviation in 1975.
