Work-package acceptance
AD status review at MRO work-package handback for management teams
When an MRO hands a work package back to an aircraft-management company, the AD portion decides whether the owner's compliance record actually advanced. This review checks the AD status list delivered with the package: which directives the visit claimed, the applicability logic behind each claim, the accomplishment records, and the method-of-compliance evidence supporting every closure. It is run for the management team and owner representative before the package is accepted as complete. Items with full support are confirmed; items without it go back to the MRO with a precise statement of what is missing, while the shop still owes the answer.
When this review is needed
- A maintenance visit closed several ADs and the management company must accept the package on the owner's behalf.
- The AD status list delivered with the package differs from the status the tracking provider shows.
- Applicability calls were made by the MRO, by serial number or modification state, without the supporting notes in the file.
- The aircraft is managed for an owner who may sell, and every AD closure will be retested by a buyer's reviewer.
The problem
Management companies accept work packages for owners who never see the paperwork, and AD closures are the part of the package with regulatory weight behind every line. The MRO's status list states conclusions; the evidence for those conclusions, the applicability worksheets, the accomplishment signoffs, and the chosen method of compliance, sits deeper in the package or does not sit there at all. Sorting conclusion from evidence takes time the handback meeting does not allow.
What gets reviewed
- Every AD the visit claims to have accomplished, terminated, or found not applicable
- Applicability determinations against the aircraft's serial number, modification state, and installed equipment
- Accomplishment records tying each closure to signed work and its date, hours, and cycles
- Method-of-compliance selections against the options the directive actually permits
- Recurring ADs reset by the visit and the next-due data handed to the tracking provider
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What gets validated
- Each closed AD has an accomplishment record naming the work performed, rather than a status-line entry alone
- Not-applicable calls cite the serial range, configuration, or modification that removes the aircraft from the directive's effectivity
- The method of compliance recorded is one the directive or an approved AMOC authorizes
- Recurring directives show the correct interval reset from the accomplishment point
- The package status list, the logbook entries, and the tracking provider's data state the same position for every directive touched
Evidence normally required
- The MRO's delivered AD status list and the underlying work package
- Aircraft applicability data: serial number, modification status, and installed equipment list
- Logbook entries and signoffs covering the visit
- The tracking provider's AD report before and after the visit
- Any AMOC approvals the aircraft relies on
Common discrepancies
- A directive marked accomplished whose only evidence is its row on the status list
- A not-applicable call resting on a modification the records never show embodied
- A recurring AD reset from the package close date rather than the inspection date
- Method-of-compliance entries citing a service bulletin revision other than the one the work followed
What is at stake
An AD accepted as closed without accomplishment evidence puts the gap on the owner's side of the ledger. It resurfaces at the next major inspection, at a pre-buy, or in a ramp-level records question, and by then the MRO's obligation to substantiate its work has faded into a commercial argument. Directives claimed closed by an inapplicable method are worse, since the correction may involve reopening physical work.
How the work runs
Extract the AD population
Pull every directive the package touches, with its claimed status and the closure evidence offered.
Test applicability and method
Check each call against serial number, configuration, and the compliance options the directive permits.
Trace accomplishments
Match closures to signed work records, dates, and utilization figures, and verify recurring resets.
Return the deficiency list
Hand the MRO the open items with the specific evidence owed, and correct the tracking handoff.
What the buyer receives
- An item-by-item AD acceptance record marking each directive supported or deficient
- A deficiency list for the MRO stating the exact evidence owed on each open item
- A corrected status handoff for the owner's tracking provider
Who uses the output
- The owner representative deciding whether to sign the package as accepted
- The management company's maintenance controller updating tracking
- Whoever presents this aircraft at its next pre-buy or insurance review
How the work fits into the transaction or program
The review slots into the handback itself, between the MRO's delivery of the package and the management company's acceptance signature. Its deficiency list is the acceptance response, and its corrected status feeds the tracking provider so the owner's compliance picture moves with the work actually evidenced.
Start with a single asset
Reconcile maintenance tracking against source records.
Jurisdiction-specific considerations
For FAA-registered aircraft, AD compliance recording obligations sit with the owner and operator under 14 CFR 91.417, whatever the MRO delivered. EASA-registered managed aircraft route the same accountability through the CAMO. In both systems the management company is accepting evidence on behalf of the party the regulation actually binds, which is why acceptance standards matter more than the shop's assurances.
Regulatory limits
The review evaluates the evidence in the package. It does not determine AD applicability on behalf of the authority, approve methods of compliance, grant or interpret AMOCs, or make the aircraft's airworthiness determination. Those determinations remain with the responsible parties under the operating rules.
What this review does not cover
Specific to this review
- Status lists are usually generated from the MRO's planning system, which records intent; accomplishment evidence comes from the floor, and the two disagree more often after workscope changes mid-visit.
- Not-applicable determinations are the least-reviewed lines on any AD list and the most expensive to be wrong about, since no work backs them up.
- The handback meeting is the only moment the MRO's substantiation duty and the management company's leverage fully overlap.
- Owners change management companies; an AD file accepted loosely by one manager becomes the next manager's inherited defect, with no one left who remembers the visit.
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
The MRO is authorized and signed for the work. Is a separate evidence check proportionate?
The MRO's authorization covers performing the work. Recording obligations for AD compliance sit with the owner and operator, and a buyer's reviewer or an authority inspector will ask the owner's side for the evidence years after the shop's involvement ends. The check is a few days against a liability with no expiry.
Relevant glossary terms
Related pages
Where this fits
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