Operator transfer status
Verifying AD compliance status in a maintenance-control system export
This review proves, or disproves, each line of the AD status list exported from a maintenance-control system. Records specialists run it when an operator transfer, fleet consolidation, or system migration makes the export the document of record. Every AD position is traced to accomplishment evidence: work orders, task cards, SB completion records, and applicability assessments held behind the export. Maintenance control receives an exception list showing which closures the source package actually supports, ready for the transfer status pack.
When this review is needed
- An aircraft is transferring between operators and the receiving CAMO will audit the AD list line by line.
- A maintenance-system migration is imminent and open questions in the AD module will be frozen into the new system.
- An internal audit sampled the AD list and the miss rate justified a full pass.
- The export shows closures inherited from a previous operator whose evidence never followed the aircraft.
The problem
An AD status export carries the authority of the system that produced it, which is exactly the problem. Compliance decisions keyed years ago, applicability calls made by staff long gone, and closures migrated from a prior system all print identically to well-evidenced lines. Maintenance control cannot tell, from the export alone, which rows would survive a challenge.
What gets reviewed
- Each AD line traced to its accomplishment record: work order, task card, or SB completion
- Method of compliance on the export compared with the method the evidence documents
- Applicability and not-applicable determinations checked for a recorded engineering basis
- Recurring AD next-due calculations recomputed from the documented accomplishment point
- Terminating actions verified against the modification or SB evidence claimed
- Superseded and revised ADs checked for correct disposition of the predecessor requirement
Scope this review
Tell us the asset, the event, and the evidence in scope, and we will outline a focused first engagement.
Send a representative, redacted record set and we will scope the review.
What gets validated
- Closure dates on the export agree with the dates on the underlying sign-offs
- Accomplishment evidence identifies the correct aircraft, engine, or component by serial number
- A recorded justification exists for every line marked not applicable
- Repetitive inspections show an unbroken accomplishment chain, without skipped intervals
- No AD position rests solely on a status inherited from a prior system without source records
Evidence normally required
- The AD status export in full, with system field definitions
- Work orders, task cards, and SB completion records behind the claimed closures
- Engineering applicability assessments and any alternative method of compliance approvals
- Utilization data needed to recompute recurring due points
- Prior-operator status documents where closures were inherited
Common discrepancies
- A closure keyed at system migration with a comment field where the evidence should be
- Terminating action claimed while the referenced SB shows only partial accomplishment
- A recurring AD whose next-due was computed from the wrong utilization basis
- Not-applicable calls made by effectivity assumption rather than a documented assessment
What is at stake
An AD shown closed without evidence is an open AD as far as any receiving operator or authority is concerned. Discovering that during transfer acceptance stalls the aircraft, forces emergency evidence hunts across shops and prior operators, and puts every other line of the status list under suspicion.
Move from findings to resolution
Move from findings to a documented resolution path.
How the work runs
Freeze the export
Fix the export date and version so every finding refers to one dataset.
Trace each line
Match AD positions to accomplishment evidence and grade the support.
Recompute recurrences
Rebuild next-due points for repetitive ADs from documented accomplishment.
Package the exceptions
Deliver graded findings and the gap register keyed to the transfer timeline.
What the buyer receives
- A substantiation report grading every AD line as supported, weak, or unsupported
- An evidence-gap register with the missing document named for each weak line
- A corrected next-due table for recurring ADs where recomputation moved the date
Who uses the output
- Maintenance control preparing the operator-transfer status package
- Receiving CAMO teams deciding what to accept and what to challenge
- Records leadership prioritizing evidence recovery before the transfer date
How the work fits into the transaction or program
AD substantiation is usually the first module of a maintenance-control export review because it carries the sharpest regulatory edge. Its findings flow into the transfer status pack alongside the LLP, release-document, and program-status reviews, and its evidence-gap register often drives the recovery effort for the whole export.
Jurisdiction-specific considerations
14 CFR Part 39 makes each AD its own regulation, and 14 CFR 91.417 requires the operator to keep the status and method of compliance. Under EASA, Regulation (EU) 1321/2014 assigns the CAMO continuing responsibility for AD status accuracy. Transfers that cross regimes need each line readable under both frameworks, because closure conventions differ.
Regulatory limits
The review reports what the evidence supports for each AD line. It does not determine airworthiness, does not approve alternative methods of compliance, and does not discharge the operator's or CAMO's own obligation to hold accurate AD status.
What this review does not cover
- Performing or certifying AD accomplishment work
- Filing for alternative method of compliance approval with any authority
- AD applicability research for aircraft outside the export under review
Specific to this review
- System migrations are where AD evidence dies: the status transfers as data, the documents stay behind as paper.
- An export can print a closure date the underlying sign-off contradicts because someone corrected the record without correcting the system.
- Recurring ADs fail review more often through due-point arithmetic than through missed inspections.
- Receiving operators sample the AD list first, so its condition sets the tone for the entire transfer audit.
Sources
U.S. Government (eCFR). The legal basis for issuing and enforcing Airworthiness Directives on U.S.-registered products.
U.S. Government (eCFR). Records an owner or operator must keep, including total time in service, current status of life-limited parts, and AD compliance.
European Union / EASA. Continuing airworthiness, maintenance records, CAMO responsibilities, and the airworthiness review process in the EASA system.
Frequently asked questions
Can the review rely on the prior operator's signed AD statement?
A signed statement is a starting point, and some receiving operators accept it commercially. As evidence it is only as good as the records behind it, so the review flags any line whose sole support is the statement, and the transfer team decides whether that risk is acceptable for the aircraft in question.
Relevant glossary terms
Related pages
Where this fits
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