AD status records for an operator AOC transfer

When this review is needed

• An aircraft is changing operator certificates and the receiving side will re-derive AD applicability from scratch.
• The transfer crosses authorities and directives from both the FAA and EASA lines apply to the type.
• A directive was closed by an alternative method of compliance and the approval for that method is not in the file.
• Recurring AD tasks were folded into the maintenance program and their next-due basis has to be provable at handover.

The problem

An AD status list is only as good as the evidence under each line, and that evidence tends to thin out on the oldest directives. When the receiving operator re-derives applicability for the serial number, it does not accept the previous status list on trust. It rebuilds the position directive by directive, and any AD closed on a summary entry, an assumed applicability, or an unfiled alternative method turns from resolved into open.

What gets reviewed

• AD applicability re-derived against the serial number, engine, and installed configuration
• Method of compliance for each directive confirmed against approved data
• Terminating action AD status checked where a modification closed a recurring requirement
• Alternative methods of compliance matched to the approval that authorized them
• Recurring AD next-due status reconciled with the maintenance program tasks that carry it
• Accomplishment evidence located for every directive shown as complied with

What gets validated

• Each applicable directive on the list has an accomplishment record behind it, not a status line alone
• Applicability decisions match the effectivity for this serial number and configuration
• Every alternative method of compliance is backed by the approval that granted it
• Terminating actions claimed as closing recurring ADs have embodiment evidence on file
• Recurring AD next-due figures agree between the status list and the program tasks

Evidence normally required

• The current AD status list for airframe, engines, and appliances
• Accomplishment records, work cards, and logbook entries closing each directive
• Approvals for any alternative methods of compliance in use
• Configuration and modification records affecting AD applicability
• The maintenance program tasks that carry recurring AD requirements

Common discrepancies

• A directive marked complied with on the status list but missing its accomplishment record
• An AD closed by an alternative method whose approval is nowhere in the file
• A recurring AD whose next-due basis differs between the status list and the program
• An applicability call that does not fit the serial number's actual configuration

What is at stake

A directive the receiving side cannot confirm as complied with goes back to open, and an open AD blocks the aircraft from the new certificate until it is closed with evidence or re-accomplished. Re-accomplishing a directive that was in fact already done, because the paperwork could not be found, costs shop time and aircraft availability for a task that never needed doing. On a transfer clock, a handful of unprovable directives can move the acceptance date.

How the work runs

What the buyer receives

• An AD evidence map tying each directive to its accomplishment record and basis
• A gap list of directives that will not survive receiving-side re-derivation, ranked by exposure
• A document request set for the missing accomplishment and approval records

Who uses the output

• Asset managers judging whether the AD position is ready to hand over
• Receiving-operator continuing-airworthiness staff re-deriving compliance for acceptance
• Records leads assembling accomplishment evidence before the transfer window closes

How the work fits into the transaction or program

This review comes between the transfer agreement and the receiving operator's re-derivation of AD status. It gets ahead of that re-derivation by closing the directives most likely to fail it, and it hands the receiving side an AD position supported by evidence rather than by a status list alone.

Jurisdiction-specific considerations

A transfer between FAA and EASA operators can bring both directive lines into play, since the receiving authority may mandate directives the sending side never tracked. The review derives applicability against the rules the receiving operator answers to, so a directive that only bites after the move is surfaced before it becomes a late finding.

Regulatory limits

The review reports what the accomplishment evidence supports for each directive. It does not determine airworthiness, approve an alternative method of compliance, close any AD, and does not replace the receiving operator's or authority's own compliance determination.

What this review does not cover

• Accomplishing or re-accomplishing any airworthiness directive
• Approving an alternative method of compliance
• Assessing physical airworthiness of the aircraft

Specific to this review

• The receiving operator re-derives AD applicability independently, so a clean prior status list carries no weight without the evidence under each line.
• The most expensive outcome is re-accomplishing a directive that was already done, forced by an accomplishment record that could not be located.
• Alternative methods of compliance are a frequent failure point because the status line survives while the approval that authorized it goes missing from the file.

Sources

Frequently asked questions

Relevant glossary terms

Related pages

Where this fits