MEL Rectification Interval expiry
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MEL Rectification Interval expiry
[FONT='Verdana','sans-serif']Colleagues
I have a question with respect to the expiry of rectification intervals defined in MMEL / MEL. I have searched all available regulating documentation without finding the answer.
Allow me to elaborate my query. Lets take an example of a MEL category A that has an RI of 2 days.
Lets say the fault was discovered on the 1st Jan, 2008 at 16:30, 1st of Jan will be the day of discovery & the count for the rectification interval will begin at 00:00 2nd Jan & expire at 23:59 3rd of Jan
My question is as follows: With no rectification carried out on the 2nd or the 3rd, is a flight programmed to depart at 23:30 3rd of Jan legal? The idea obviously being that the MEL is cleared when the A/C arrives at the maintenance base at 07:00 on the 4th....
My personal thoughts are that this flight cannot be programmed because the MEL expires inflight & should be taken into consideration during dispatch. All I have found supporting my theory is a document that Airbus published to aid operators in understanding concepts used in the MMEL/MEL. Below is the link (see page 40)
http://www.flightlevel400.com/docume...dMEL220705.pdf
The thing is I havent been able to find any regulatory documentation describing or clarifying this concept
I would like to know the communities' thoughts on this & if anyone knows where I may be able to find official documentation that clarifies this issue.....
Thanks[/FONT]
I have a question with respect to the expiry of rectification intervals defined in MMEL / MEL. I have searched all available regulating documentation without finding the answer.
Allow me to elaborate my query. Lets take an example of a MEL category A that has an RI of 2 days.
Lets say the fault was discovered on the 1st Jan, 2008 at 16:30, 1st of Jan will be the day of discovery & the count for the rectification interval will begin at 00:00 2nd Jan & expire at 23:59 3rd of Jan
My question is as follows: With no rectification carried out on the 2nd or the 3rd, is a flight programmed to depart at 23:30 3rd of Jan legal? The idea obviously being that the MEL is cleared when the A/C arrives at the maintenance base at 07:00 on the 4th....
My personal thoughts are that this flight cannot be programmed because the MEL expires inflight & should be taken into consideration during dispatch. All I have found supporting my theory is a document that Airbus published to aid operators in understanding concepts used in the MMEL/MEL. Below is the link (see page 40)
http://www.flightlevel400.com/docume...dMEL220705.pdf
The thing is I havent been able to find any regulatory documentation describing or clarifying this concept
I would like to know the communities' thoughts on this & if anyone knows where I may be able to find official documentation that clarifies this issue.....
Thanks[/FONT]
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using your example then i say no it is not legal as the AC will be flying with a defect outside of the MEL time frame...... it also depends on the companies MOE/MPM and wether the mel can be extended - but TBH if its a mel A item i doubt it.
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No problem in the flight being scheduled but it should not depart until that defect is rectified.
As soon as the MEL limit expires the aircraft no longer remains airworthy.
From JAR OPS
As soon as the MEL limit expires the aircraft no longer remains airworthy.
From JAR OPS
b) An Operator shall not operate an Aeroplane
other than in accordance with the MMEL unless
permitted by the Authority. Any such permission
will in no circumstances permit operation outside
the constraints of the MMEL
other than in accordance with the MMEL unless
permitted by the Authority. Any such permission
will in no circumstances permit operation outside
the constraints of the MMEL
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This actually depends on the procedure your company has lead down in the MEL and which is required to be approved by the respective DGAC / CAA.
Inside JAR it is possible that you have the option to have the Tech. Director to approve an extension for the very same period as the MEL originally limited the item; i.e. in your case, the Technical Director may approve to operate with the deferred rectification until 5th January 23:59
Other operators (due to authorities) need prior approval from the respective CAA to defer the rectification for the same period or shorter, as case may be decided.
In both scenarios the extension has to be mentioned and signed by an authorized engineer near the entry in the ADD listing.
In any case, the aircraft is not allowed to be dispatched nor operated outside the approved and signed deferred rectification period.
Inside JAR it is possible that you have the option to have the Tech. Director to approve an extension for the very same period as the MEL originally limited the item; i.e. in your case, the Technical Director may approve to operate with the deferred rectification until 5th January 23:59
Other operators (due to authorities) need prior approval from the respective CAA to defer the rectification for the same period or shorter, as case may be decided.
In both scenarios the extension has to be mentioned and signed by an authorized engineer near the entry in the ADD listing.
In any case, the aircraft is not allowed to be dispatched nor operated outside the approved and signed deferred rectification period.
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From this end of the Pond, and wih my operator, it is legal to operate that flight. So long as the aircraft departs before midnight EST or EDT, as applicable, the aircraft can operate. Of course, it dies at its destination, even if it diverts for some reason.
I'll look for the pertinent regulation or document and post the reference if it is FAA, after I get some sleep. It's daytime here.
I'll look for the pertinent regulation or document and post the reference if it is FAA, after I get some sleep. It's daytime here.
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MEL RIE Procedure
This is an extract from a CAP 549 (2003) dealing with the construction of an MEL.
"5 Rectification Intervals
Inoperative items or components, deferred in accordance with the MEL, must be
rectified at or prior to the Rectification Intervals established by the following letter
designators given in the " Rectification Interval Category " column of the MEL.
Category A
No standard interval is specified, however, items in this category shall be rectified in
accordance with the conditions stated in the remarks column (5) of the MEL.
Where a time period is specified in calendar days or flight days, the period shall start
at 00:01 on the calendar day following the day of discovery.
Category B
Items in this category shall be rectified within three (3) consecutive calendar days,
excluding the day of discovery.
Category C
Items in this category shall be rectified within ten (10) consecutive calendar days,
excluding the day of discovery.
Category D
Items in this category shall be rectified within one hundred and twenty (120)
consecutive calendar days, excluding the day of discovery.
Rectification Interval Extensions (RIEs)
Subject to the approval of the CAA, the operator may use a procedure for the
extension of the applicable Rectification Intervals B, C and D, for the same duration
as specified in the MEL in accordance with CAP 549."
I feel sure it has been revised since then. But at the time I wrote a CAME for a regional airline and had the RIE procedure accepted for the airline. I may have a copy at home - I will check after work.
Hope this helps
MB
`
"
"5 Rectification Intervals
Inoperative items or components, deferred in accordance with the MEL, must be
rectified at or prior to the Rectification Intervals established by the following letter
designators given in the " Rectification Interval Category " column of the MEL.
Category A
No standard interval is specified, however, items in this category shall be rectified in
accordance with the conditions stated in the remarks column (5) of the MEL.
Where a time period is specified in calendar days or flight days, the period shall start
at 00:01 on the calendar day following the day of discovery.
Category B
Items in this category shall be rectified within three (3) consecutive calendar days,
excluding the day of discovery.
Category C
Items in this category shall be rectified within ten (10) consecutive calendar days,
excluding the day of discovery.
Category D
Items in this category shall be rectified within one hundred and twenty (120)
consecutive calendar days, excluding the day of discovery.
Rectification Interval Extensions (RIEs)
Subject to the approval of the CAA, the operator may use a procedure for the
extension of the applicable Rectification Intervals B, C and D, for the same duration
as specified in the MEL in accordance with CAP 549."
I feel sure it has been revised since then. But at the time I wrote a CAME for a regional airline and had the RIE procedure accepted for the airline. I may have a copy at home - I will check after work.
Hope this helps
MB
`
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Basically all you're asking the is if ALL maintenance action items require to be valid at T/O only or flight duration and Landing.
This must stand for OOP's, Daily, ADD's, concessions etc.
I was always under the impression that the C of A required all items to be serviceable with enough time remaining to complete the entire flight.
JAR-OPs should cover this.... I'm off for a look
This must stand for OOP's, Daily, ADD's, concessions etc.
I was always under the impression that the C of A required all items to be serviceable with enough time remaining to complete the entire flight.
JAR-OPs should cover this.... I'm off for a look
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Thanks for your input guys
Its strange that at some airlines this concept is considered acceptable & is common practice (the airline I work at included)
My understanding in this regard has always been that it is not OK to release an aircraft in this condition
1- An aircraft cannot commence a flight without a valid maintenance release covering the entire period of the proposed flight, certifying that all required maintenance as been carried out & certified on the aircraft
2- The maintenance release must also consider permissable unserviceabilities (MELs) and previous maintenance releases
Unless I'm mistaken in my understanding of this concept, the flight that I mention is illegal
I took this up with our Quality manager & even he thinks that as long as the flight takes off before midnight, its legal. From what he explains, European regulations are more strict & the FAA regulations allow you to make that last flight. I havent been able to find any documentation however that clarifies this
Cheers
Its strange that at some airlines this concept is considered acceptable & is common practice (the airline I work at included)
My understanding in this regard has always been that it is not OK to release an aircraft in this condition
1- An aircraft cannot commence a flight without a valid maintenance release covering the entire period of the proposed flight, certifying that all required maintenance as been carried out & certified on the aircraft
2- The maintenance release must also consider permissable unserviceabilities (MELs) and previous maintenance releases
Unless I'm mistaken in my understanding of this concept, the flight that I mention is illegal
I took this up with our Quality manager & even he thinks that as long as the flight takes off before midnight, its legal. From what he explains, European regulations are more strict & the FAA regulations allow you to make that last flight. I havent been able to find any documentation however that clarifies this
Cheers
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OK I see mixed reactions to this post
I got a followup question for Fr8Mech & ASFKAP
We all agree that even though the rectification interval for MEL is in days, the issue I'm talking about comes to the last moments before expiration hence we're looking at it from an hours standpoint
Lets take the case of a 400H check. The Aircraft is at a station 8 hours away from the base & at 398 hours. Using the same logic shouldnt I be able to bring the A/C back to base & execute the check upon arrival??
I got a followup question for Fr8Mech & ASFKAP
We all agree that even though the rectification interval for MEL is in days, the issue I'm talking about comes to the last moments before expiration hence we're looking at it from an hours standpoint
Lets take the case of a 400H check. The Aircraft is at a station 8 hours away from the base & at 398 hours. Using the same logic shouldnt I be able to bring the A/C back to base & execute the check upon arrival??
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In your original example you did not specify what CAT A time frame is used.
As an example for an FDR fault the MEL will state a limitation on the time say 3 flight days This means if the aircraft remains on the ground for a week, you could then operates the aircraft every other day in this case the MEL entry would be valid for 13 days You can use any combination you want but the bottom line is that limitation is based on flight days
However if the MEL stipulates 6 calender days then at the end of this period it must be fixed or a concession obtained.
It is only applicable to CAT A item because all other categories are based on calender days only
Regarding service checks the rules are black and white on this if a check will expire in flight the check must be done before it takes to the air unless you obtain an extension to the check such that it expire on the ground
As an example for an FDR fault the MEL will state a limitation on the time say 3 flight days This means if the aircraft remains on the ground for a week, you could then operates the aircraft every other day in this case the MEL entry would be valid for 13 days You can use any combination you want but the bottom line is that limitation is based on flight days
However if the MEL stipulates 6 calender days then at the end of this period it must be fixed or a concession obtained.
It is only applicable to CAT A item because all other categories are based on calender days only
Regarding service checks the rules are black and white on this if a check will expire in flight the check must be done before it takes to the air unless you obtain an extension to the check such that it expire on the ground
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Actually I only used Cat A in the example so people wouldnt bring RIE (extensions) etc into the picture
And youre mistaken about the Cat A being restricted to Flight Days. While the Cat A doesnt have a defined RI unlike the other categories, it can be Flight Days, Calender Days, Flight Cycles or even Flight Hours, The major distinction (other than the fact its variable) is that it cannot be extended (RIEs donot apply to Cat A MELs) - neither JAA nor FAA allows this
Independently though, my point was specific to the final moments before expiration (considering the count - be it flight day or calender day has already begun & is about to expire)
And youre mistaken about the Cat A being restricted to Flight Days. While the Cat A doesnt have a defined RI unlike the other categories, it can be Flight Days, Calender Days, Flight Cycles or even Flight Hours, The major distinction (other than the fact its variable) is that it cannot be extended (RIEs donot apply to Cat A MELs) - neither JAA nor FAA allows this
Independently though, my point was specific to the final moments before expiration (considering the count - be it flight day or calender day has already begun & is about to expire)
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RI Expires....?
The situation you describe should be covered in the Pre amble to the MEL.
Additionally the OPs Manual will give you the answer - or should do!
From my experience in compiling both MELS and CAMES for a number of operators, the effective day of an MEL item commences at mid night on the day it was discovered and terminates at midnight on the last day of permitted operation. If your organisation has an approved RIE procedure then an extension of the original RI would/could be granted by the agreed signatory to the RIE, normally a senior Pilot, i.e.Fleet captain.
MB
Additionally the OPs Manual will give you the answer - or should do!
From my experience in compiling both MELS and CAMES for a number of operators, the effective day of an MEL item commences at mid night on the day it was discovered and terminates at midnight on the last day of permitted operation. If your organisation has an approved RIE procedure then an extension of the original RI would/could be granted by the agreed signatory to the RIE, normally a senior Pilot, i.e.Fleet captain.
MB
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What I mention here is not stipulated neither in Ops manual, nor in regulation documentation. All that is explained is how the RI is calculated Calender day, like you say midnight following day of discovery etc.....
& like i mentioned, RIE's donot apply to MEL As
& like i mentioned, RIE's donot apply to MEL As
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Operation of the aircraft is not allowed after expiry of the Rectification Interval
specified in the MEL, unless:
a) the defect has been rectified; or
b) the Rectification Interval is extended in accordance with paragraph 8 below
Extract from CAP 549 Para 7.3
Same statement in JAR-MMEL/MEL.080 (c)
So like the service check mentioned earlier same procedure applies
specified in the MEL, unless:
a) the defect has been rectified; or
b) the Rectification Interval is extended in accordance with paragraph 8 below
Extract from CAP 549 Para 7.3
Same statement in JAR-MMEL/MEL.080 (c)
So like the service check mentioned earlier same procedure applies
Last edited by Engineer; 22nd Feb 2008 at 21:54.
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MEL RI's
Just recieved the latest rev to the B767 (Rev5) CAA MEL Supplement and copied this from the Pre-Amble.
It should close the 'start/finish' question of an MEL item, and is as stated earlier.
The Note at the end shows the RIE extension conditions, i.e the operator must have an approved system in place to operate an RIE procedure.
`
`
""Rectification Interval" (Column 2) : Inoperative items or components, deferred in accordance with theMEL, must be rectified at or prior to the rectification intervals established by the following letter designators given in the "Rectification Interval" column (2) of the MMEL.
`
[I]Category A
No standard interval is specified, however, items in this category shall be rectified in accordance with the conditions stated in the Remarks column (5) of the MMEL.
Where a time period is specified it shall start at 00:01 on the calendar day following the day of discovery.
Category B
Items in this category shall be rectified within three (3) consecutive calendar days, excluding the day of discovery.
For example, if it was recorded at 10 am on January 26th, the three day interval would begin at midnight on the 26th and end at midnight on the 29th.
Category C
Items in this category shall be rectified within ten (10) consecutive calendar days, excluding the day of discovery. For example, if it was recorded at 10 am on January 26th, the 10 day interval would begin at midnight on the 26th and end at midnight on February 5th.
Category D
Items in this category shall be rectified within one hundred and twenty (120) consecutive calendar
days, excluding the day of discovery.
Note: The operator may permit, with Authority agreement, a one-off extension to the applicable rectification interval B, C or D for the same duration as that specified in the MMEL, in accordance with JAR MMEL/MEL.[
/I]Cheers
MB
It should close the 'start/finish' question of an MEL item, and is as stated earlier.
The Note at the end shows the RIE extension conditions, i.e the operator must have an approved system in place to operate an RIE procedure.
`
`
""Rectification Interval" (Column 2) : Inoperative items or components, deferred in accordance with theMEL, must be rectified at or prior to the rectification intervals established by the following letter designators given in the "Rectification Interval" column (2) of the MMEL.
`
[I]Category A
No standard interval is specified, however, items in this category shall be rectified in accordance with the conditions stated in the Remarks column (5) of the MMEL.
Where a time period is specified it shall start at 00:01 on the calendar day following the day of discovery.
Category B
Items in this category shall be rectified within three (3) consecutive calendar days, excluding the day of discovery.
For example, if it was recorded at 10 am on January 26th, the three day interval would begin at midnight on the 26th and end at midnight on the 29th.
Category C
Items in this category shall be rectified within ten (10) consecutive calendar days, excluding the day of discovery. For example, if it was recorded at 10 am on January 26th, the 10 day interval would begin at midnight on the 26th and end at midnight on February 5th.
Category D
Items in this category shall be rectified within one hundred and twenty (120) consecutive calendar
days, excluding the day of discovery.
Note: The operator may permit, with Authority agreement, a one-off extension to the applicable rectification interval B, C or D for the same duration as that specified in the MMEL, in accordance with JAR MMEL/MEL.[
/I]Cheers
MB
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MEL time restrictions and calendar day/hour restrictions for checks are different. Our MEL procedures allow for departure up to midnight of the expiration date. Our lowest level check above the daily allows the same. As far as I know, evey other check must arrive before the drop dead time/day.
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Hi friends, I have question. My fellow mechanic raise interesting question. As per discussed in this session, everybody understand that the MEL time clocking starts at 0:00 of the next day of the "discoverty".
My question is:
Q1) If defect is found in c-check, and it was impossible to rectify the defect, the starting potint of the MEL should be the next day of A/C RTS signed-off?
Q2) Or should the starting point still be next day of the discovery?
Q3) Some of my colleague suggested MEL is originally intended for the use of operation (not for maintenance) and applying MEL meant degrade of the system redundancy, so, it is normal to have the attitude to fix such defect until dock-out. Yes, but if the parts not arrived and need to A/C back to base, what's happen?
If any regulatory guide line exists for such scenario, please let me know (if you can post the web link, it is very happy).
My question is:
Q1) If defect is found in c-check, and it was impossible to rectify the defect, the starting potint of the MEL should be the next day of A/C RTS signed-off?
Q2) Or should the starting point still be next day of the discovery?
Q3) Some of my colleague suggested MEL is originally intended for the use of operation (not for maintenance) and applying MEL meant degrade of the system redundancy, so, it is normal to have the attitude to fix such defect until dock-out. Yes, but if the parts not arrived and need to A/C back to base, what's happen?
If any regulatory guide line exists for such scenario, please let me know (if you can post the web link, it is very happy).
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I don't understand any of this discussion. Safety first full stop. The answer to the main question is that the aircraft must arrive airworthy in terms of known defects and scheduled items.
Why allow yourself to be compromised?
Please read and understand the dirty dozen especially the one about assertiveness.
Why allow yourself to be compromised?
Please read and understand the dirty dozen especially the one about assertiveness.
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BCAR you appear to have got the wrong end of the stick. MEL reliefs are used to allow an aircraft to continue in service with a defect. The MEL is not a maintenance document it is a FLT OP's controlled document and agreed with the Authority. For this reason the Deferred Defect Record is examined by the FLT CREW and may depart a station with an active MEL relief provided it has not expired. Should it expire in flight it may continue but cannot depart again as the aircraft is no longer serviceable unless the MEL relief is extended or cleared.