Preparing the export
Airworthiness Directive status review for airlines preparing an export
Before an airline requests an export certificate of airworthiness, this review confirms the AD status list will withstand the scrutiny that follows. Each AD line is checked for applicability logic, method of compliance, accomplishment evidence, and, for recurring directives, a defensible next-due figure. Records specialists run it during export preparation, typically in the weeks before the certificate request. Fleet engineering receives a line-item verification table, a register of unresolved lines, and a tracker for the source documents still to be pulled.
When this review is needed
- An aircraft sale requires an export certificate and the AD list has never faced outside review.
- Directives were closed by SB embodiment years ago and the accomplishment records sit in archived check packages.
- The buyer's technical team has started sampling AD lines and asking for source evidence.
- AMOCs approved for the airline's certificate underpin several lines and their transferability is unclear.
The problem
An AD status list grows over years of fleet operation, compiled by different people against changing tools, and the export is the first time an outside party reads it line by line. Applicability calls made long ago may rest on configuration assumptions nobody documented, and directives closed by SB embodiment point at accomplishment records buried in old check packages. The export timetable rarely allows for archaeology once the certificate request is filed.
What gets reviewed
- Applicability determinations for each AD against the aircraft's actual configuration and modification state
- Method of compliance recorded per line, including AMOCs and their approval references
- Accomplishment evidence for terminated directives, traced to the check package or work order
- Recurring AD next-due values recomputed against current hours, cycles, and calendar time
- Superseded and revised directives, confirming the list reflects the current regulatory text
- SB-based closures, verifying the bulletin sign-off supports the AD terminating action
Scope this review
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What gets validated
- Every not-applicable call carries a stated reason tied to configuration or serial effectivity
- Terminating actions cite an accomplishment record that exists and matches the aircraft
- Recurring lines show next-due figures consistent with the utilization report as of the compile date
- AMOC references resolve to an approval naming this operator or this aircraft
- No directive issued since the last compile is missing from the list
Evidence normally required
Common discrepancies
What is at stake
A challenged AD line stalls the entire export package, and the exporting airline carries the burden of proof. Buyers and receiving authorities treat one unsupported line as reason to sample harder, so a single missing accomplishment record can convert a routine export into a line-by-line defense of the whole list.
How the work runs
Baseline the list
Fix the compile date, utilization basis, and regulatory revision level the status was built against.
Verify applicability
Test not-applicable and configuration-based calls against the modification records.
Sample accomplishments
Pull accomplishment evidence for a risk-weighted sample, biased to terminating actions and recent revisions.
Close and hand over
Issue the verification table and drive the unresolved register down before the certificate request.
What the buyer receives
- A line-item verification table marking each AD as supported, unsupported, or open
- A register of unresolved lines with the specific document needed to close each
- A source request tracker assigning retrieval owners and dates ahead of the certificate request
Who uses the output
- Fleet engineering finalizing the export package
- Technical-records leadership answering buyer and authority queries
- The continuing-airworthiness manager signing behind the status
How the work fits into the transaction or program
AD verification anchors the export records package because most receiving authorities and buyer teams start there. Closing weak lines before the certificate request keeps the export survey focused, and the verified table becomes the reference the airline defends questions from during delivery.
Start with a single asset
Prove the review on a single tail, then scale across the fleet.
Jurisdiction-specific considerations
14 CFR Part 39 makes ADs binding for US-registered aircraft, and EASA operates a parallel directive system with its own applicability and AMOC mechanics under Regulation 1321/2014. Where the aircraft is heading to the other system, the review flags lines whose compliance basis is authority-specific, since the receiving side will re-read them under its own rules.
Regulatory limits
The review verifies documentation. It does not issue applicability rulings, approve AMOCs, perform or certify AD accomplishment, or make the airworthiness determination behind the export certificate.
What this review does not cover
- Physical inspection to confirm embodiment on the aircraft
- Preparing or filing the export certificate application
- Engineering development of new AMOC requests
Specific to this review
- AMOCs are approved to a specific applicant, so a line compliant today can become undocumented compliance for the buyer the day after transfer.
- Terminating action via SB requires both the bulletin's accomplishment sign-off and an AD status entry that cites it; either alone leaves the line open to challenge.
- Next-due arithmetic fails quietly when the status compile lags the utilization report, which is why both dates are checked together.
- Receiving authorities sample where the list looks weakest; a handful of clean corrections before filing changes how deep the sampling goes.
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
How large a sample gets verified against source records?
Sampling is risk-weighted rather than fixed-percentage. Terminating actions, recently revised directives, and lines closed by SB embodiment get pulled first because they fail most often; clean results there justify lighter sampling of routine recurring lines.
Relevant glossary terms
Related pages
Where this fits
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