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VOLUME 20 CONTINUOUS AIRWORTHINESS MAINTENANCE PROGRAM

CHAPTER 6 REQUIRED INSPECTIONS

Section 1 Evaluating Required Inspection Item (RII) Procedures

Source Basis:
General
§ 1.1, General Definitions.
§ 43.3, Persons Authorized to Perform Maintenance, Preventive Maintenance, Rebuilding, and
Alterations.
§ 43.5, Approval for Return to Service After Maintenance, Preventive Maintenance,
Rebuilding, or Alteration.
§ 43.7, Persons Authorized to Approve Aircraft, Airframes, Aircraft Engines, Propellers,
Appliances, or Component Parts for Return to Service After Maintenance, Preventive
Maintenance, Rebuilding, or Alteration.
§ 43.9, Content, Form, and Disposition of Maintenance, Preventive Maintenance, Rebuilding,
and Alteration Records (Except Inspections Performed in Accordance with Part 91, Part 125,
§ 135.411(a)(1), and § 135.419 of This Chapter).
§ 43.13, Performance Rules (General).
§ 43.16, Airworthiness Limitations.
Part 91K Part 121 Part 135
§ 91.1015, Management § 119.49, Contents of § 119.49, Contents of
Specifications Operations Specifications Operations Specifications
§ 119.65, Management § 119.69, Management
Personnel Required for Personnel Required for
Operations Conducted Under Operations Conducted Under
Part 121 of This Chapter Part 135 of This Chapter
§ 91.1023, Program Operating § 121.133, Preparation § 135.21, Manual
Manual Requirements Requirements
§ 91.1025, Program Operating § 121.135, Manual Contents § 135.23, Manual Contents
Manual Contents
§ 121.137, Distribution and
Availability
§ 121.139, Requirements for
Manual Aboard Aircraft:
Supplemental Operations
§ 91.1413(a) and (b)(3), § 121.363, Responsibility for § 135.413, Responsibility for
CAMP: Responsibility for Airworthiness Airworthiness
Airworthiness

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§ 91.1423, CAMP: § 121.365, Maintenance, § 135.423, Maintenance,

Maintenance, Preventive Preventive Maintenance, and Preventive Maintenance, and
Maintenance, and Alteration Alteration Organization Alteration Organization
Organization
§ 91.1425, CAMP: § 121.367, Maintenance, § 135.425, Maintenance,
Maintenance, Preventive Preventive Maintenance, and Preventive Maintenance, and
Maintenance, and Alteration Alteration Programs Alteration Programs
Programs
§ 121.368, Contract § 135.426, Contract
Maintenance Maintenance
§ 91.1427, CAMP: Manual § 121.369, Manual § 135.427, Manual
Requirements Requirements Requirements
§ 91.1429, CAMP: Required § 121.371, Required § 135.429, Required
Inspection Personnel Inspection Personnel Inspection Personnel
§ 91.1431, CAMP: Continuing § 121.373, Continuing § 135.431, Continuing
Analysis and Surveillance Analysis and Surveillance Analysis and Surveillance
§ 91.1433, CAMP: § 121.375, Maintenance and § 135.433, Maintenance and
Maintenance and Preventive Preventive Maintenance Preventive Maintenance
Maintenance Training Program Training Program Training Program
§ 91.1435, CAMP: Certificate § 121.378, Certificate § 135.435, Certificate
Requirements Requirements Requirements
§ 91.1437, CAMP: Authority to § 121.379, Authority to § 135.437, Authority to
Perform and Approve Perform and Approve Perform and Approve
Maintenance, Preventive Maintenance, Preventive Maintenance, Preventive
Maintenance and Alterations Maintenance, and Alterations Maintenance, and Alterations
§ 91.1439, CAMP: § 121.380, Maintenance § 135.439, Maintenance
Maintenance Recording Recording Requirements Recording Requirements
Requirements
§ 91.1443, CAMP: § 121.709, Airworthiness § 135.443, Airworthiness
Airworthiness Release or Release or Aircraft Log Entry Release or Aircraft
Aircraft Maintenance Log Maintenance Log Entry
Entry

20-6-1-1 REPORTING SYSTEM(S).

A. Safety Assurance System (SAS). For Title 14 of the Code of Federal Regulations
(14 CFR) part 121 or 135, use SAS automation and the associated Data Collection Tools (DCT).

B. SAS Activity Recording (AR). For 14 CFR part 91 subpart K (part 91K), use
activity code 3330, 3341, 5330, or 5341, as appropriate.

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20-6-1-3 OBJECTIVE. This section provides policy, information, and guidance that aviation
safety inspectors (ASI) must use when evaluating the required inspection procedures of a
Continuous Airworthiness Maintenance Program (CAMP).

NOTE: Required inspections constitute 1 of the 10 required elements of a

CAMP. The manual must designate items that require inspection, and contain
required inspection procedures, instructions, controls, standards, and limits that
are acceptable to the Administrator.

20-6-1-5 EXPLANATION OF TERMS, DEFINITIONS, AND REGULATIONS.

A. CAMP Operator. Within Volume 20, the term “CAMP operator” is used to refer to
both part 91K program managers and part 121 or 135 certificate holders (CH) issued operations
specification (OpSpec)/management specification (MSpec) D072. When Volume 20 uses the
term “CH,” it is only referencing parts 121 and 135. When Volume 20 uses the term program
manager, it is only referencing part 91K.

B. Manual. The term “manual” within this section refers to the documents identified
and listed in a D072 specification. These documents in their entirety, which include guidance and
information incorporated by reference, constitute the maintenance part of the manual required by
part 91, § 91.1023; part 121, § 121.133; and part 135, § 135.21.

C. D072 Specification. Unless otherwise noted, the term “D072 specification” when
used in Volume 20 refers to a part 91K program manager’s MSpec D072 or a part 121 or 135
CH’s OpSpec D072 authorization, as applicable.

D. Designation. Designation is the act of indicating or identifying specifics, a calling

out. The regulations require designation of safety-critical items of maintenance or alteration that
require inspection, and designation by occupational title of personnel with the authority to
perform each required inspection. The manual procedures depicting how to identify
safety-critical items and the identification of the personnel authorized to perform the inspections
of them should be clear and unmistakable.

E. Ensure. To ensure requires the manual to include or reference a comprehensive

method of compliance that when followed produces the required output.

F. Function.

1) Maintenance, per the 14 CFR part 1, § 1.1 definition, includes inspection.

However, the regulations (for safety reasons) separate required inspections from maintenance.
Required inspection regulations describe the requirements for a CAMP operator’s maintenance
organization in the context of separation of the maintenance function from the required
inspection function. These regulations depict the action of performing maintenance, preventive
maintenance, or alterations as functions that must be performed separately from those functions
designated as required inspections.

2) Secondly, the regulations depict the action of performing the actual required
inspection as a function. The term “function” is expanded here to indicate the performance of the
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required inspection at the prescribed point at which, during or after the performance of the
required inspection maintenance task, the required inspection is accomplished in accordance with
the CAMP operator’s required inspection procedures and instructions. CAMP operators should
have and identify required inspection instructions in their manual, depicting when the required
inspection function is performed for each required inspection, at a predetermined point within the
maintenance task, to ensure a specific, consistent, and detailed inspection is accomplished.

3) The necessity to specify the point of the task at which the required inspection
must be performed is significant because often that function or step within the task cannot be
verified after the entire task has been completed.

G. Incorporation by Reference. Instead of repeating information contained in another

document, a CAMP operator may incorporate information from a document or part thereof as
their method of compliance, by referring and/or providing links to it in the text of their manual.
In doing this, the CAMP operator takes ownership of the incorporated information, and it carries
the same weight and significance as if it was written by the CAMP operator.

H. Inspection Unit.

1) The inspection unit is a component of the CAMP operator’s maintenance

organization. Sections 91.1423(b), 121.365(b), and 135.423(b) require this organizational
subgroup, which must be adequate to perform the work of required inspections. The manual
must, per §§ 91.1427(a), 121.369(a), and 135.427(a), contain a chart or description of the
organizational structure and a list of persons with whom it has arranged for the performance of
any of its required inspections and other maintenance, preventive maintenance, or alterations,
including a general description of that work.

2) The manual also, per §§ 91.1427(b)(8), 121.369(b)(8), and 135.427(b)(8),

requires instructions and procedures to prevent any decision of an inspector regarding any
required inspection from being countermanded by persons other than supervisory personnel of
the inspection unit. This subgroup the manual charts or describes and lists, identifying all persons
with the authority to perform required inspections, is the CAMP operator’s inspection unit. No
person (per §§ 91.1429(b), 121.371(b), and 135.429(b)) may perform required inspections unless
they are under the supervision and control of the inspection unit and/or Chief Inspector (when
required). The Director of Maintenance (DOM) has overall responsibility for the management of
both the required inspection functions and the other maintenance, preventive maintenance, or
alterations functions.

I. Item. Item (as it relates to the CAMP required inspection element) is a distinct step in
a series or process that requires a detailed and focused inspection.

J. Required Inspection. A required inspection is a comprehensive description and

detailed inspection, described through documented instructions contained in the manual.

K. Proper Maintenance. Proper maintenance means performing maintenance and

alterations in accordance with the method of compliance in the manual.

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L. Proper Parts or Materials. This means the parts and/or materials used to perform
maintenance and alterations are those prescribed by the manual.

M. Task. Task, as used in this guidance, depicts high-level maintenance, preventive

maintenance, or alteration work assignments (e.g., installation or rigging of an engine, landing
gear, or flight controls). Work orders, job cards, or task forms are methods of compliance CAMP
operators use to meet the whole of §§ 91.1427(b), 121.369(b), and 135.427(b). These methods
identify, organize, and assign the systematic accomplishment of the items (e.g., specific
procedures, instructions, standards, and limits) that are necessary to achieve the overarching
maintenance, preventive maintenance, or alteration job assignment.

20-6-1-7 GENERAL. Aircraft manufacturers do not designate items as RII. RII designation is
the duty of operators who must or choose to operate at the highest levels of safety (i.e., CAMP
operators). A person who is required or who chooses to maintain their aircraft under a CAMP
has accepted the duty to provide their services with the highest possible degree of safety in the
public interest. This duty subjects them to performance-based regulations that places the
responsibility for the airworthiness and reliability of their aircraft directly on them. They do not
share this responsibility with manufacturers, design approval holders (DAH), or the Federal
Aviation Administration (FAA). Performance-based regulations require them to produce a
manual that is comprehensive in scope and detail and that directs personnel in the performance
of all maintenance, preventive maintenance, and alteration. While CAMP operators may derive
maintenance (including inspection), preventive maintenance, and alteration information from
product and article manufacturers, they are responsible for ensuring it is effective in maintaining
the airworthiness of their aircraft. CAMP operators must be willing and able to design, maintain,
and ensure the effectiveness of the CAMP methods and procedures, including those they
incorporate by reference. Only the CAMP operator knows the effect their operation has on their
aircraft. The CAMP operator must have and maintain a system to identify if their CAMP is
ineffective, and have the ability to quickly revise, supplement, or correct manual content
(including incorporated content) when they identify discrepancies. A manual that is vague, only
repeats performance-based terminology, or incorporates information by reference without
providing specific direction, instruction, and methodology to maintain it, is a safety risk and is
not acceptable to the Administrator.

A. Required Inspections.

1) Unlike other inspections, a required inspection (function) is specific to items that

are critical to the safety of flight. They can also have a history such as improper performance, or
may be complicated, complex, or missed. A required inspection is a detailed examination of in-
process maintenance and alteration work by an appropriately certificated, properly trained,
qualified, and authorized person. This person is separate from the maintenance process and,
during the period of time while accomplishing the required inspection, is under an inspection
unit’s supervision and control.

2) The purpose of the required inspection is to validate proper performance of the

overall maintenance task and to verify the appropriate use of parts and materials. Persons
conducting required inspection functions must do so in accordance with specific procedures
contained in the manual. Required inspections are safety controls mandated by regulation, which

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the CAMP operator must designate to ensure maintenance and alteration performance is at the
highest level of safety possible.

B. Items that Require Inspection. An item that requires inspection (i.e., RII) is a
distinct, safety-critical step within a maintenance or alteration process that requires a
well-defined inspection by a designated person to validate the proper performance of
maintenance and use of proper parts and materials. Regulations require designation of items
(process steps) of maintenance and alteration, that if performed incorrectly, or parts or materials
are used improperly, could result in a failure, malfunction, or defect that would endanger the safe
operation of the aircraft. RII designation can also ensure proper performance of complicated
maintenance and alteration processes and ensure proper performance and accomplishment of
process steps that are prone to human error. It is the duty of all CAMP operators to designate
these items.

C. Section Purpose and Outline.

1) CAMP acceptance and authorization is a standardized process, explained in

Volume 3, Chapter 1, Section 1. This process requires ASIs to perform a detailed analysis,
review, and evaluation of the operator’s CAMP proposal (i.e., manual), followed by ASI
observations of the operator’s performance of their manual procedures, guidelines, and
parameters. Once accepted, ASIs will use the manual in conjunction with their knowledge of the
regulations to conduct required inspection performance observations, records reviews, and
surveillance to validate the design as effective.

2) An effective design ensures compliance with regulations and high levels of safety.
The purpose of this section is to provide detailed procedures for ASIs to use when assessing the
CAMP required inspection element design and observing its performance. The section provides
ASIs with information that conveys FAA expectations in regards to the required inspection
element of a CAMP.

20-6-1-9 PROCEDURES FOR CAMP REQUIRED INSPECTION ORGANIZATION.

Establishment and performance of good required inspection procedures can only be successful if
the organization is adequate to support them. Accident investigations have identified inadequate
organizations as a causal factor that led to poor performance of required inspections. Ineffective
required inspections that were conducted but which failed to identify when improper
maintenance had been performed have led to aircraft loss of control, resulting in an accident and
loss of life. CAMP operators must exercise diligence to ensure their maintenance organization is
adequate to support the performance of required inspections. ASI assessment of the CAMP
operator’s maintenance organization is a process that must continue as the CAMP operator (and
its operation) evolves and changes.

A. The Manual Chart or Description of the CAMP Organization.

1) Sections 91.1427(a), 121.369(a), and 135.427(a) require the CAMP operator to

put in its manual a chart or description of its organization, as required by §§ 91.1423, 121.365,
and 135.423. ASIs should be able to identify within the organization those who perform the work
of required inspections. The manual must also include a list of persons with whom it has

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arranged for the performance of its required inspections, including a general description of
that work.

2) When evaluating the manual for compliance with this requirement, the ASI
should ensure that the respective manual contains procedures to keep this information current
and available to the FAA for inspection. The manual contents must also be readily available for
use by the CAMP operator’s personnel that need this information to perform their jobs, such as
persons involved in contract maintenance, alterations, training, or auditing.

B. Assessing an Adequate CAMP Organization. The CAMP regulations go beyond

simply providing a description or chart of the CAMP organization in the manual. The
organization (by regulation) must also be adequate. Sections 91.1423(a), 121.365(a),
and 135.423(a) prescribe organizational requirements for CAMP operators, as applicable. Each
CH that performs, and each program manager that has its personnel perform, any of its
maintenance (other than required inspections), preventive maintenance, or alterations as well as
each person with whom they arrange for the performance of that work must have an organization
adequate to perform that work. Sections 91.1423(b), 121.365(b), and 135.423(b) require the
applicable CAMP operator and/or person with whom it arranges to perform inspections required
by its manual (herein referred to as required inspections) to have an organization adequate to
perform that work.

1) Organizational Separation of Functions. The inspection organization is

responsible for determining that both the workmanship and materials used conform to the
regulations and the manual. Sections 91.1423(c), 121.365(c), and 135.423(c) contain an
additional requirement for organizing the performance of the maintenance function and the
required inspection function to separate the inspection functions from the other maintenance,
preventive maintenance, and alteration functions. The separation must be below the level of
administrative control at which overall responsibility for the required inspection function and
other maintenance, preventive maintenance, and alteration functions is exercised.

2) Assessing Adequacy. In making the determination of an adequate organization, it

is important for an ASI to note that the regulations do not specify the number of required
inspection personnel a CH, program manager, or other persons must have. Additionally,
§§ 91.1423(c), 121.365(c), and 135.423(c) recognize that the CAMP operator or other persons
can use personnel for both maintenance and required inspections. In determining organizational
adequacy, the CAMP operator and evaluating ASI should consider the regulatory phrase
“adequate to perform the work.” CAMP operators must understand their duties, and ASIs should
take into account the legal requirement to perform services with the highest possible degree of
safety.

3) Required Inspection Personnel. The CAMP operator, or the person with an

arrangement to perform required inspections for the CAMP operator, must maintain a current
listing of persons who are trained, qualified, and authorized to conduct required inspections.
Sections 91.1429, 121.371, and 135.429 are prescriptive requirements directed at the person who
uses (assigns or directs) any person to perform required inspections. These apply to both the
CAMP organization and essential maintenance providers (EMP) who have an arrangement to
perform required inspections for the CAMP operator.

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4) Authorization to Perform Required Inspections. The CAMP operator that

directs, assigns, or uses any person to perform required inspections is responsible for ensuring
that the person it uses meets the regulatory requirements and CH’s or program manager’s
procedures in its manual. The CH or program manager must ensure it grants required inspection
authorization only to persons trained, qualified, and holding an appropriate airman certificate.
There are no regulatory shortcuts for authorizing an individual on a one-time basis. As such, the
procedures for authorizing any person must be applied in each instance.

5) Certificate Responsibility and Authority.

a) The term “appropriate” within the context of the required inspection

requirements refers to a Mechanic Certificate with Airframe and Powerplant (A&P) ratings, or a
Repairman Certificate issued by either an air carrier authorized to maintain aircraft under a
CAMP or a certificated repair station. The person holding a Repairman Certificate may only
perform functions, which may include required inspections, if they are authorized under the
limitations of the Repairman Certificate. All CAMP operators must ensure the people they use to
perform a required inspection are appropriately certificated.

b) However, in regards to a part 121 or 135 Air Carrier Certificate Holder, the
person is not exercising the privileges of his or her airman certificate. The authority to perform
the required inspection is from the Air Carrier Certificate. In regards to part 91K, the part 91K
program manager, unless properly certificated, may not perform or approve maintenance for
return to service. The authority to perform the required inspection under part 91K is from the
program manager’s or other person’s Mechanic Certificate, or by a certificated repairman
performing maintenance through an authorized repair station.

6) Maintenance Providers. If the CAMP operator uses other persons to perform

required inspections, the manual must provide methods to assess their ability, and then authorize
and list them. The manual must describe in detail the method (which includes documentation)
the CAMP operator uses to assess a maintenance provider organization to determine if it is
adequate to perform required inspections for them. Regardless of whether CAMP operator
personnel perform the required inspections or they authorize a maintenance provider to perform
them, the manual policies, procedures, methods, and instructions must be acceptable to the FAA
and ensure that, when followed by the maintenance provider, the performance of all maintenance
(including required inspections) is in accordance with the manual and the regulations.
Volume 20, Chapter 8 includes procedures to evaluate maintenance providers.

C. Defining the Level of Administrative Control.

1) The level at which persons exercise overall responsibility for the required
inspection function and other maintenance, preventive maintenance and alteration functions is
typically the position identified as the DOM or equivalent. Regardless of the title, it is a position
required by 14 CFR part 119 and is regarded by the FAA as having primary authority and
responsibility over the entire CAMP. As such, the Chief Inspector position and/or the inspection
personnel, if present within the CAMP operator’s organization, would fall, organizationally,
under the control and authority of the DOM position.

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2) Therefore, the part 119 DOM position is that level of administrative control at
which overall responsibility for required inspection functions and other maintenance, preventive
maintenance, and alteration functions is exercised. The maintenance or alteration functions, as
well as the designated required inspection functions, would be performed below the DOM
position.

D. Required Managerial Positions. While the regulations do not define the number of
required inspection personnel, the regulations clearly depict the required managerial positions for
the CAMP operator’s maintenance organization. Part 119, §§ 119.65 and 119.69 prescribe the
requirements for parts 121 and 135, respectively. Section 91.1413 stipulates part 91K program
manager management requirements.

1) CHs under part 121 must have a DOM and a Chief Inspector, or equivalent
positions. The DOM is responsible for the entire maintenance organization, while the Chief
Inspector is responsible for the inspection organization. This is separate from the maintenance
organization but still falls under the overall responsibility of the DOM.

2) Part 135 CHs are only required to have a DOM, per § 119.69. Under part 135, the
regulations provide greater flexibility and scalability of the maintenance organization. A Chief
Inspector is not a required position for part 135 CAMP operators.

3) Section 91.1413 stipulates that part 91K program managers maintaining aircraft
under a CAMP must employ both a DOM and Chief Inspector, or equivalent positions.

E. Personnel Designated to Perform Required Inspections.

1) Occupational Titles. Sections 91.1427(b)(3), 121.369(b)(3), and 135.427(b)(3)

require CAMP operators to include in their manual a designation by occupation title of personnel
authorized to perform each required inspection. Examples of occupational titles that evaluating
ASIs may find in the manual include aircraft mechanic, aircraft inspector, aircraft maintenance
supervisor, and aircraft maintenance foreman.

2) Required Inspection Personnel. Sections 91.1429(a), 121.371(a),

and 135.429(a) specify that no person may use any person to perform required inspections unless
the person performing the required inspection meets certification and training requirements, and
has been qualified and authorized by the CAMP operator to perform the inspection.

F. Separation of Required Inspection Functions.

1) In the context of §§ 91.1423, 121.365, and 135.423, “separation” specifically

refers to the function of performing the required inspection, which must be distinctly performed
by persons that are not involved in performing the maintenance or alteration task. The
regulations require a separation between the performance of required inspection functions and
the associated maintenance or alteration functions. The most direct means to ensure separation of
functions is to establish full-time inspection and maintenance departments. However, this does
not mean that doing so is the only option.

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2) The focus of separation is on the person performing the required inspection. The
CAMP operator’s procedures and controls should be strong enough to ensure that any person
assigned to perform the inspection, or persons with whom the CAMP operator has arranged to
perform the required inspection, are not involved in performing the maintenance or alteration
work task designated as an RII. Separation of the inspection function does not mandate a specific
organizational structure to create that separation. Rather, it prevents persons performing the
required inspection from performing any of the maintenance involved in the required inspection.

G. Inspection Units. Sections 121.371(b) and 135.429(b) state that no person may allow
any person to perform a required inspection unless, at that time, the person performing that
inspection is under the supervision and control of an inspection unit. While part 91 does not
mandate an inspection unit, § 91.1429(b) does require that persons performing required
inspections must be under the supervision and control of the Chief Inspector. ASIs should
understand that the FAA considers the organizational subgroup required by §§ 91.1423(b),
121.365(b), and 135.423(b) to be the inspection unit, and it must be adequate to perform the
work of required inspections. The manual must, per §§ 91.1427(a), 121.369(a), and 135.427(a),
contain a chart or description of the CAMP operator’s organizational structure. This subgroup,
which their manual charts or describes as including persons with the authority to perform
required inspections, is their inspection unit. The individuals in this subgroup must be identified
on lists required by §§ 91.1429(d), 121.371(d), and 135.429(e). It is the CAMP operator’s
responsibility to describe its maintenance organization, to include the inspection unit, in their
manual. The performance-based nature of the regulations require the CAMP operator to establish
in the manual the structure of their organization. ASIs should consider the following when
evaluating the organization in regards to required inspections:

1) Full-Time Inspection Units. The inspection unit may consist of full-time

inspectors within the CAMP operator’s maintenance organization working under the supervision
and control of the Chief Inspector. As noted earlier, the Chief Inspector is a position required for
part 121 air carriers and part 91K operators, but is not required under part 135.

2) Temporary Inspection Units. Alternatively, the inspection unit may be

described as a temporary organizational structure that is put into effect when performing a
required inspection. Often, this involves cross-utilization of maintenance personnel to perform
required inspections.

3) Regulatory Compliance. Regardless of whether the inspection unit is full-time,

or established temporarily when performing an inspection, the evaluating ASI must ensure the
CAMP operator clearly describes how it complies with the regulations in part 91K, 121, or 135,
as applicable, which are consistent in prohibiting the person performing a required inspection
from performing the work to be inspected. Further, the required inspection must be performed
separately from maintenance functions and under the supervision and control of an inspection
unit (or the Chief Inspector for part 91K).

4) Inspection Unit Organization. The intent of the inspection unit is to ensure the
proper performance of maintenance. A person under different supervisory control and leadership,
who did not perform any item of the maintenance work, provides an unbiased inspection of that
work. With larger CAMP operators and maintenance providers, it is typical for them to establish

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and identify an inspection unit as a separate department or unit within the maintenance
organization.

a) However, in smaller organizations without dedicated, full-time personnel

working within a structured inspection unit, it is incumbent upon the CAMP operator to clearly
define the organizational structure in its manual and describe how it controls the separation
between the maintenance and required inspection functions, to ensure unbiased inspections are
performed.

b) For part 135 CAMP operators, this may be depicted as a virtual organization
that reports directly to the DOM and is only in effect when performing the required inspection.
In these cases, the person performing the required inspection is no longer accountable to the
maintenance department, but is directly accountable to the DOM.

5) Inspection Unit Management. If the DOM is the only maintenance person

employed by the CAMP operator, then all other maintenance and inspection personnel would
likely be contracted to perform work on its behalf. It is critical for the manual to describe how it
will arrange, organize, manage, and administer control over these contract maintenance providers
(CMP) with a full explanation as to how it will ensure that any contracted persons performing
required inspections will be controlled and supervised within an inspection unit. These smaller
CAMP operators may need to consider various methods, such as establishing a temporary
inspection unit that is only active when a required inspection is performed.

a) Under this structure, when a separate inspection organization does not exist, a
certificated and authorized maintenance technician can be repositioned from the maintenance
unit to the inspection unit temporarily to perform the required inspection. This certificated person
could also be acting (at the time of the inspection) as the supervisor of the inspection unit. This
provides for the separation in functions at the appropriate level by shifting the person assigned to
perform a required inspection from the control of the maintenance unit to the control of an
inspection unit.

b) The DOM continues to have overall responsibility over the entire maintenance
organization that includes the certificated and authorized inspector and the (other) maintenance
technician that performed the maintenance work requiring inspection. Concurrently, just as the
procedures must be incorporated into the manual to define this change in control, there should
also be a description of the duties and responsibilities associated with each assigned position.

6) Parts 91K and 121 Chief Inspectors. For part 91K operators with a CAMP,
§ 91.1429(b) specifies that required inspections must be performed under the supervision and
control of the Chief Inspector. Similarly, part 119 requires that part 121 CHs must have a Chief
Inspector. These managerial position requirements form the basis for a definitive inspection unit
within the respective maintenance Chief Inspector. Notwithstanding these managerial position
requirements, the regulations do not require a full-time, separate inspection department. It is very
important that the evaluating ASI verify that the manual describes its organization and provides
the procedures and controls that will ensure separation between the inspection and maintenance
functions.

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7) Part 135 Inspection Units. Part 135 CAMP operators are not required to have a
Chief Inspector. A part 135 CAMP operator’s maintenance organization may only consist of the
DOM. While not obligated to have dedicated inspection personnel or a full-time inspection
department (or unit), they are responsible for meeting the requirement to separate the required
inspection functions from other maintenance functions. The DOM is the person with overall
authority of both the inspection and maintenance functions and as such, may not perform the
required inspection. Therefore, in very small organizations the certificated person performing the
required inspection could be, by themselves, the “inspection unit” under which they are working
and being supervised. As noted above, the evaluating ASI must verify that the manual describes
its organization and provides the procedures and controls that will ensure separation between the
inspection and maintenance functions.

8) Cross-Utilization, Change in Control. In cases where the CAMP operator or

other persons cross-utilize personnel to perform both maintenance and inspection functions, the
evaluating ASI should note how the manual describes the actual change in the control of that
person from the maintenance unit to the control of the inspection unit. Evaluating ASIs will need
to ensure that smaller CAMP operators that cross-utilize persons to perform both maintenance
and inspection functions have established procedures that will accommodate and ensure that
separation is evident when a required inspection is to be performed.

H. RII Supervision. Sections 91.1429(b), 121.371(b), and 135.429(b) call for the
supervision of the person performing the required inspection. The evaluating ASI should
understand that the regulations direct compliance at the person with authority and responsibility
for allowing (assigning or directing) another person to perform the required inspection. For
part 91K, the supervisor is the Chief Inspector. For all other CAMP operators, this person might
be a manager, supervisor, or maintenance controller who assigns work. This individual is
responsible for ensuring that the person he or she assigns or allows to perform the required
inspection is under the supervision and control of an inspection unit at the time he or she
performs the required inspection. In a smaller organization that consists of just a few
maintenance technicians, the certificated, authorized, and listed person performing the required
inspection may at the time of the inspection comprise the entire inspection unit.

1) Safety Intent of Inspection Unit.

a) The intent of the regulation is to ensure the person performing the required
inspection is not subject to the same pressures, circumstances, and assumptions as the person
performing the item of work. The inspection unit’s only responsibility is to ensure the materials
used and maintenance performance are proper and correct. Regardless of who is allowed to
assign required inspection functions, the evaluating ASI must determine that the procedures
establish a mechanism (control) that ensures the person performing the inspection is under the
supervision and control of an inspection unit, not the maintenance controller or maintenance unit.

b) Evaluating ASIs should verify the manual describes how it and other persons
it uses to perform required inspections will comply with this requirement. It is important for both
management and maintenance personnel to know and understand this principle and recognize the
authority and control of the inspection unit for required inspections.

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2) Inspection Unit Supervisor.

a) Although the regulations do not specify a requirement for an inspection unit

supervisor, it is both logical and apparent in the reading of the regulations under part 121 and to
some extent, parts 91 and 135. Additionally, it is supported by the requirements in
§§ 91.1423(b), 121.365(b), and 135.423(b) for an organization to be considered adequate to
perform required inspection functions. The supervisor may be the Chief Inspector or any other
qualified person the CAMP operator chooses, particularly for part 135 CAMP operators that
incorporate a full-time inspection unit into their maintenance organization.

b) However, it is important that the supervisor be separate from the maintenance

unit in responsibility, authority, and interest to ensure the independent nature of the required
inspection. The evaluating ASI will need to verify that the CAMP operator describes in its
manual the requirements necessary to ensure compliance with these regulations for itself and any
other persons that perform required inspections for it.

3) Organizational Separation (Small CAMP Operations). If a part 135 CAMP

operator only employs the DOM, its manual must still contain a description of the maintenance
and inspection organization that ensures the separation of maintenance and inspection functions.
Because the separation must be below the level of administrative control at which overall
responsibility for the required inspection functions and other maintenance, preventive
maintenance, and alteration functions is exercised, the DOM may not perform work designated
as RII, nor can he or she perform the required inspection of that work.

20-6-1-11 PROCEDURES FOR RII DESIGNATION. RII designation is a safety

management process that is specific to maintenance and alteration work. It is the duty of the
CAMP operator to identify items of maintenance and alteration that must be inspected (required
inspections), including at least those that could result in a failure, malfunction, or defect
endangering the safe operation of the aircraft, if not performed properly or if improper parts or
materials are used. Inspectors should validate that the manual describes how the operator makes
these decisions and how they designate items that require inspection. Designation is a safety
control that must be clear to those who are performing the work. These controls must ensure that
only a person designated to do so performs the required inspection.

A. The Manual Should Describe the Method of Designating RII Using Risk-Based
Decision Making (RBDM).

1) Responsibility. Sections 91.1413, 121.363, and 135.413 establish CAMP

operators as primarily responsible for maintaining the airworthiness of their aircraft in
accordance with their CAMP, regardless of who performs the work. Volume 20, Chapter 1,
Section 1 explains primary responsibility and the sublevel duties that are in the interest of safety,
which the regulations require of operators who maintain aircraft subject to a CAMP.

2) Identifying Safety-Critical Items (Higher Level of Safety).

a) Aircraft manufacturers do not designate items as required inspections in the

Aircraft Maintenance Manual (AMM). Rather, designation of a required inspection is a CAMP
operator’s duty. Designation is mandated by §§ 91.1427(b)(2), 121.369(b)(2), and 135.427(b)(2).
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To assess the manual’s method to designate items of maintenance that require inspection, ASIs
must understand all of §§ 91.1427(b), 121.369(b), and 135.427(b). Sections 91.1427(b)(1),
121.369(b)(1), and 135.427(b)(1) require the manual to include the method of performing routine
and nonroutine maintenance (other than required inspection), preventive maintenance, and
alterations. Sections 91.1427(b)(3), 121.369(b)(3), and 135.427(b)(3) require the manual to
include the method of performing required inspections, and designation by occupational title of
personnel authorized to perform them.

b) ASIs need to review the manual and validate that it includes procedural
methods to perform a safety analysis of all maintenance and alteration tasks and processes, with
a method to designate (identify) specific maintenance or alteration items that are safety-critical.
Designation of these items must be clear and distinct in the work instructions for those
performing maintenance and alteration duties. When determining maintenance and alteration
tasks as RIIs it is important that the CH or program manager considers and accounts for the
phrases “at least those,” “that could result,” and “improper parts or materials.”

c) The FAA considers the phrase “at least those” as a strong indicator that each
CAMP operator will identify certain tasks that meet the criteria of a required inspection. Some
CHs or program managers may contend that their programs do not include tasks that meet
criteria of a required inspection. ASIs should not accept or authorize a CAMP that does not
include any designated RII. Required inspections correlate directly with flight safety.

d) Therefore, the CAMP operator should consider all of its required inspections
with the same safety of flight consideration and emphasis, even if accomplishing an individual
required inspection adversely affects its flight schedule, relates to a scheduled or an unscheduled
task, arises at an awkward time during a maintenance visit, or must be performed at an
inconvenient location. Evaluating ASIs should ensure the manual has procedures on how it
makes RII determinations, who is authorized and accountable for determining RIIs, and how it
revises or amends its program to integrate items that require inspection. The CAMP operator
should base its methods for RII determination on regulatory requirements.

3) Common Designations.

a) Notwithstanding the importance of all required inspections, special attention

should be given to required inspections involving flight control systems. RII determinations
should take into account such things as failure consequences resulting from improperly
performed maintenance or alterations, and the use of improper parts and materials. The CAMP
operator might consider using the expertise of the aircraft manufacturer and manufacturer’s
instructions from the technical maintenance documents that are reflected in notes, cautions,
warnings, comments, or alerts, or otherwise identified as significant steps in the
maintenance task.

b) These are a good indication that there are aspects of the maintenance task that
if done improperly, could result in an unsafe condition. Additionally, the National Transportation
Safety Board’s (NTSB) Aviation Accident Database and Synopses contains accident information
relating to required inspection failures, which can be useful. However, the responsibility for
determining and listing required inspections remains with the CAMP operator. Some examples

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of required inspection functions that may be called for when performing associated maintenance
tasks identified as a required inspection are:

• Proper torque and retention device installation for engine and landing gear
mounting hardware;
• Correct travel, cable routing, tensioning, hardware fitting/torque, and
retention device installation for flight control surfaces; and
• Post-installation activation and rigging for certain emergency equipment
installations.

4) Required Inspection Scope.

a) The evaluating ASI should ensure that the CAMP operator’s designation of
RIIs is not too broad in scope, or solely comprised of a listing of generalized overall maintenance
or inspection tasks, such as replacing or rigging primary flight controls, replacing or rigging
landing gear, or engine installations (see Figure 20-6-1A, Sample Inadequate Designation of
RIIs). Designations of this nature are generic and would not be acceptable unless they also
include a depiction of the specific items within those tasks to be inspected as the focus of the
required inspection. While these tasks are significant, such generalized listings alone do not meet
the intent of the regulation.

b) Regardless of whether or not the CAMP operator has a generalized listing of

tasks as required inspections, the procedures in their manual must further identify the items
(i.e., functions or steps within the tasks) that are the target of the required inspections (see
Figure 20-6-1B, Sample Unacceptable Depiction of Inspection Method/Requirements). In order
to maintain its significance, the list of required inspections should not be broad or overly
inclusive. Instead, the CAMP operator should identify specific items of inspection for each
aircraft make and model it operates. It is inappropriate to designate entire systems or tasks as
RIIs.

5) On-Wing vs. Off-Wing. FAA policy has typically applied required inspection
requirements to those maintenance tasks performed on the aircraft (i.e., on-wing) in lieu of those
performed on articles or components that are not installed on an aircraft (i.e., off-wing).
However, for the purpose of required inspections, regulations do not discriminate between
maintenance tasks performed on-wing and maintenance tasks performed off-wing. Therefore,
CAMP operators that wish to do so must not be restricted from designating off-wing
maintenance tasks that meet required inspection criteria as a required inspection. See Volume 20,
Chapter 8 for more information.

6) Required Inspection Procedures. The manual may reference a specific chapter,

page, or paragraph in the AMM for step-by-step inspection instructions. However, using an
AMM reference does not negate the CAMP operator’s responsibility to ensure the procedures are
comprehensive, detailed, and effective. The evaluating ASI should not accept generalized
instructions that make nonspecific references to the AMM for procedures intended to cover all
required inspections.

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7) Continuing Analysis Surveillance System (CASS) and RII Designation.

During certification, the CAMP operator must provide a document that explains their safety
analysis method and the items they initially designate as requiring inspection. FAA review,
observation, and acceptance of this method during certification validates it as acceptable to the
Administrator, and establishes and authorizes its use with the issuance of the D072 specification.
This safety analysis and item designation method of compliance then becomes a function of the
CAMP operator’s CASS. This enables the CAMP operator to routinely survey CAMP
performance, analyze CAMP effectiveness, and designate new items or revise previous items
designated as items that require inspection. A manual that does not include a continuous safety
analysis method of maintenance and alteration tasks and processes, and a method to designate
safety-critical items that require inspection, is not acceptable to the Administrator.

B. RII Designation (Identification/Callout).

1) Designation (Identification/Callout). How the manual designates

(identify/callout) items of maintenance and alteration that require inspection must be clear and
distinguishable, provide sufficient controls to prevent overlooking or inadvertently skipping
them, and provide a means to document their accomplishment by a person designated to do so.
ASIs should examine manual methods that assign and document work procedures instructions
and standards (e.g., work orders, work card instructions, and task cards) and validate that the RII
designation is clear and unmistakable within them. Advisory Circular (AC) 120-16, Air Carrier
Maintenance Programs, provides a means, but not the only means, of compliance for designation
of RII that is acceptable to the Administrator. Methods such as overarching graphs and tables
that do not identify the specific item of maintenance or alteration that requires inspection are not
acceptable.

2) Standardized RII Listings and Other Industry Resources.

a) The required inspection regulations are written as performance-based

requirements, and do not provide a standardized list of required inspection items (tasks).
Considering the numerous maintenance systems being used and different configurations of the
same make and model aircraft, a standardized list would inevitably conflict with some programs
and ultimately diminish the CAMP operator’s obligation to be primarily responsible for the
airworthiness of its aircraft. Some organizations within the aviation industry have pursued the
concept of standardized RII lists.

b) For example, Airlines for America (A4A) has published ATA Spec 108,
Required Inspection Item (RII) Best Practices. Among other things, this specification offers a
standardized RII list based on collaborative data from air carriers that operate common
equipment and have similarities in their respective RII lists and procedures. ATA Spec 108 also
provides decision-making tools and recommendations for identifying required inspections with a
primary objective of sharing this data among other air carriers and seeking concurrence from the
FAA, with an expectation that these standardized lists would be found to be acceptable to the
FAA.

c) Notwithstanding these efforts by industry, such standardized lists may result

in required inspection procedures that are incomplete or otherwise do not align with the

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regulatory requirements and the FAA’s expectations for program content. One of the primary
purposes for this expanded and clarified section of guidance is to clearly articulate FAA policy
for evaluating ASIs, thus ensuring they understand that required inspection procedures must
include more than just listings of the RII (task).

d) Specifically, the manual must contain the procedures for performing every
required inspection function, which will be unique for each air carrier or operator. In addition,
the procedures must depict the standards that establish the inspection criteria, and the associated
limits for acceptance or rejection of each required inspection. These requirements do not lend
themselves to common tasks or standardized instructions or procedures. Rather, the rules specify
that the CAMP operator is responsible to designate its RIIs along with the appropriate supporting
procedures, and that it is responsible for the results.

e) Therefore, ASIs evaluating the required inspection portion of a CAMP should

not be influenced on whether or not industry-generated lists and internal procedures were used
by the CAMP operator. The FAA has no regulatory authority to require that an operator adopt a
given RII list, nor does an operator’s responsibility for required inspection requirements end by
adopting a so-called standardized list. The FAA’s acceptance of the CAMP operator’s required
inspection procedures depends on the determination that the procedures meet the criteria
prescribed in this chapter.

20-6-1-13 REQUIRED INSPECTION METHODS, PROCEDURES, INSTRUCTIONS,

STANDARDS, AND LIMITS. The expected outcome of the ASI’s evaluation using this
guidance is a validation that the manual includes detailed and well-defined methods of
performing required inspections, along with the associated procedures, instructions, standards,
and limits for determining acceptance or rejection. These methods are mandated manual content
requirements as stated in §§ 91.1427(b)(3)–(9), 121.369(b)(3)–(9), and 135.427(b)(3)–(9). As
these are performance-based regulations, the means of determining acceptance is established
through FAA policy and guidance (see paragraph 20-6-1-7).

A. Method of Performing Required Inspections.

1) CAMP Required Inspection Methodology. When reviewing the manual

required inspection element, ASIs need to see each designated item of maintenance or alteration
(per §§ 91.1427(b)(2), 121.369(b)(2), and 135.427(b)(2)), and validate the item has associated
with it a method of performing the required inspection. Sections 91.1427(b)(1) and (3),
121.369(b)(1) and (3), and 135.427(b)(1) and (3) segregate the methods of performing required
inspections from the methods of performing other maintenance, preventive maintenance and
alterations, which aligns with the CAMP organizational requirements in §§ 91.1423, 121.365,
and 135.423. The overarching intent of the performance-based regulations §§ 91.1427(b),
121.369(b), and 135.427(b) is for the CAMP operator to assume responsibility (through their
manual) for all maintenance, preventive maintenance, and alteration actions taken to attain,
maintain, and ensure their aircraft are airworthy.

2) Required Inspection Methods of Compliance. CAMP required inspection

methods of compliance are specific to the person who is seeking acceptance and authorization to
use them. The person must design the prescriptive step-by-step methods that personnel who work

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under their authorization must follow in order to ensure compliance with the CAMP
performance-based regulations, document them in a document or set of documents, and present
them to the FAA in a form acceptable to the Administrator. Upon acceptance of the entire
CAMP, the FAA issues a D072 specification, establishing the document or set of documents as
the maintenance part of the person’s manual, as required by §§ 91.1023, 91.1025, 91.1427,
121.133, 121.137, 121.369, 135.21, 135.23, and 135.427, referred to herein as the manual.

3) Incorporation by Reference.

a) Instead of repeating information contained in another document, a CAMP

operator may incorporate information from a document or part thereof as their method of
compliance, by referring or providing links to it in the text of their manual. In doing this, the
CAMP operator takes ownership of the incorporated information. It carries the same weight and
significance as if written by the CAMP operator. This means the CAMP operator (and through
oversight, the FAA) must ensure it contains the prescriptive methods, techniques, and practices
individuals must follow when performing their assigned duties.

b) The CAMP operator is responsible for this information and must provide the
most current state of the information to those who are required to use and follow it. Information
incorporated by reference is subject to CAMP operators’ CASS. Therefore, when CASS
identifies deficiencies in the referenced information, the manual must describe a means to revise,
supplement, or change the referenced material accordingly and ensure the performance and
effectiveness of the corrected information. The CAMP operator has the primary responsibility to
correct, revise, or supplement information incorporated by reference.

4) Unacceptable Methods. ASIs evaluating the required inspection process should

not accept methods that are generalized listings. Often manuals depict the methods together with
a corresponding table or chart that contains a list of generalized tasks that are designated as RII
(see Figure 20-6-1B). Such tables present a safety risk in that they lack a methodical attempt to
correlate a required inspection with a method to be used for that inspection. A list of generalized
inspection methods meant to be used as a “pick-list,” from which one or more listed methods are
selected and referenced in a corresponding RII list, does not provide the objective and specific
step-by-step detailed instructions necessary to conduct each unique required inspection. ASIs are
cautioned against accepting any generalized required inspection procedures, tables, or
instructions exhibiting the following conditions:

• The RII list is a generalized listing of high-level tasks that does not identify a
specific function, part, or area that is the focus of the required inspection.
• The procedures include a table of methods as a generalized listing of typical
conditions that would be used when performing an inspection. The
instructions do not reflect the unique method or step-by-step procedure for
performing a specific inspection on a distinct and specific function within the
designated RII.
• The information does not provide or include the standards or limits for each
required inspection, by which the RII inspector makes a determination of
acceptance or rejection.

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• The procedures and instructions are subjective and do not ensure that each
required inspection will be performed in a consistent and repeatable manner.

5) Sample of Inadequate RII Designations. The following figures give examples

of an unacceptable designated RII list (Figure 20-6-1A) and a corresponding unacceptable list of
generalized methods (Figure 20-6-1B) that are intended to depict how to perform the required
inspection. These two figures represent inadequate, and therefore, unacceptable required
inspection processes. They do not meet FAA guidance or regulatory requirements. The listed
required inspections in Figure 20-6-1A do not identify the specific function within the task that is
to be the target of the inspection. In addition, they do not contain or reference specific
instructions or procedures for performing the inspection. Further, the figure that stipulates the
methods (Figure 20-6-1B), is no more than a general depiction of how to perform any inspection.
The charts are intended to be used by the RII inspector to perform required inspections. They
lack any step-by-step instructions and the standards or limits are not depicted. The information
would result in subjective, inconsistent inspections that fail to meet the intent of the regulations
on required inspections.

Figure 20-6-1A. Sample Inadequate Designation of RIIs

Required Inspection Items Inspection Method

(See Figure 20-6-1B)
a. Installation/replacement, rigging/adjustment, or major repair of the
following flight control components and/or flight control systems:
i. Primary control surfaces (ailerons, elevators, rudder, and their
1, 2, 3, 4
actuators).
ii. Tabs (control, balance, trim, actuators, and dampers). 1, 2, 3, 4
iii. Horizontal stabilizer and actuator. 1, 2, 3, 4
iv. Flaps and actuators. 1, 2, 3, 4
v. Spoilers and actuators. 1, 2, 3, 4
vi. Hydraulic/electric actuating units or assemblies of the above
1, 2, 3, 4
systems.
vii. Related components (cables, pulleys, linkages, hinges) of the
1, 2, 3, 4
above systems.
b. The installation/replacement of any propulsion engine or Auxiliary
1, 2, 3, 4
Power Unit (APU).
c. The installation/replacement or rigging/adjustment of propulsion
3, 4
engine fuel control units.
d. Installation/replacement, rigging/adjustment, or major repair of the
following landing gear components:
i. Landing gear extension system (normal and emergency). 1, 2, 3, 4
ii. Main landing gear assembly (strut, braces, and links). 1, 2, 3, 4
iii. Nose landing gear assembly (strut, braces, and links). 1, 2, 3, 4

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Figure 20-6-1B. Sample Unacceptable Depiction of Inspection Method/Requirements

Number
Inspection Methods/Requirements
Designator
General Visual Inspection:
1 • Perform a general visual inspection. Check for proper installation, security,
safety, standard wiring practices (when applicable), and workmanship.
Materials:
• Check for proper materials, fasteners’ conformance to specifications per
2
structural repair, maintenance, or other relevant manual, or applicable
Engineering Change Order (EO) instructions.
Rigging and Torque Verification:
• Verify proper rigging and/or torque was accomplished per manual
tolerance.
3
• Validate per installation and rigging section of manual. Inspector verifies
that proper torque of the item was applied and within specified standards
and limits.
Operational, Functional, Leak Test, and Nondestructive Testing (NDT):
4 • Verify or observe proper operational, functional, leak test, and NDT
performed, within manual tolerances, as applicable.

6) Sample of Adequate RII Designations. Figure 20-6-1C, Sample Depiction of a

Designated RII Using a Task Card, and Figure 20-6-1D, Sample Method to Perform the
Required Inspection, provide examples of acceptable ways to depict a designated RII. Each
figure identifies the specific function within the task that requires an inspection. In this example,
Figure 20-6-1C shows a task card that has the appropriate step-by-step details for performing the
inspection. The task card number correlates with the associated RII task. The sample task card
(Figure 20-6-1D) provides a means of depicting the method to perform the inspection and the
correlating standards and limits.

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Figure 20-6-1C. Sample Depiction of a Designated RII Using a Task Card

Required Inspection Items RII Task Card

ATA 27 Number
a. The major repair, major alteration, installation/replacement, or
rigging/adjustment of the primary flight control, components, and/or
flight control systems:
i. Primary flight control (ailerons). FC27-001-220
ii. Primary flight control (aileron cables). FC27-001-240
iii. Primary flight control (aileron actuators). FC27-001-260
iv. Primary flight control (elevator). FC27-001-420
v. Primary flight control (elevator cables). FC27-001-440
vi. Primary flight control (elevator actuators). FC27-001-460

Figure 20-6-1D. Sample Method to Perform the Required Inspection

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B. Designation by Occupational Title of Personnel Authorized to Perform Each

Required Inspection.

1) Requirement. Performance-based regulations §§ 91.1427(b)(3), 121.369(b)(3),

and 135.427(b)(3) require the manual to designate by occupation title personnel authorized to
perform each required inspection. This aligns with the prescriptive regulations in §§ 91.1429(d),
121.371(d), and 135.429(e).

2) Listing of Required Inspection Personnel. The CAMP operator is responsible

for maintaining a current listing of persons who have been trained, qualified, and authorized to
conduct required inspections. An EMP or CMP may maintain this list. However, the CAMP
operator is responsible for the list and its currency. The list must be made available for
inspection by the Administrator upon request, regardless of who maintains it. The list must
identify each person with required inspection authority by name, occupational title, and
inspections they are authorized to perform. Each person with required inspection authority must
have written information from the CAMP operator or the EMP/CMP, as applicable, describing
the extent of that person’s responsibilities, authorities, and inspectional limitations. Examples of
occupational titles that evaluating ASIs may find in the manual include aircraft mechanic,
aircraft inspector, aircraft maintenance supervisor, and aircraft maintenance foreman.

C. Procedures, Standards, and Limits Necessary for Required Inspections and

Acceptance or Rejection of the Items Required To Be Inspected.

1) Requirement. Sections 91.1427(b)(5), 121.369(b)(5), and 135.427(b)(5) require

the CAMP operator to include in its manual the procedures, standards, and limits necessary for
required inspections and acceptance and rejection of the items required to be inspected. The
evaluating ASI must verify that the CAMP operator has clearly defined the procedures for each
required inspection in its manual, so that regardless of which authorized inspection personnel
perform the required inspection, it will always be conducted in a repeatable and consistent
manner.

2) Development. Required inspections are not found in the Original Equipment

Manufacturer (OEM) manuals, since required inspections do not apply to manufacturers.
However, when a CAMP operator develops the procedures, standards, and limits for required
inspections, they should derive their procedures and any drawings from the aircraft
manufacturer’s manual and use them in its own manual. Additionally, CAMP operators should
consider including individual required inspection signoff requirements for postrigging
verification. The CAMP operator should write its required inspection procedures in a manner
that ensures consistency by clearly stating at a minimum what to look at (items of maintenance
and alterations), how to look at it (method/means), what to compare it to (standard), and what is
acceptable or not (limits).

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3) Evaluate Procedures. When evaluating a CAMP operator’s required inspection

procedures, the ASI should be able to ascertain when and how to perform each required
inspection.

a) If performed during a maintenance task or part of a scheduled maintenance

check, the CAMP operator should have controls in place to prevent any subsequent maintenance
from invalidating the required inspection. It might be necessary to perform the inspection at a
specified step in the maintenance function to prevent such things as skin, panels, or doors from
covering the inspection item.

b) Similarly, the procedures may indicate to perform the required inspection at

the end of the task following completion of work. If performed at the completion of the work
task, it is vital that the person performing the required inspection function get a detailed
hand-down from the person who performed the work, rather than relying on just the maintenance
signoff. Sometimes maintenance personnel move, disconnect, or disturb other things to gain
access to the intended maintenance or alteration task.

c) Although the required inspection is a focused inspection, the person

performing it must be aware of the general condition of the work area. If the inspector is not
aware of these things, improper maintenance can go unnoticed. The CAMP operator should
include in its manual its communication requirements for required inspection and maintenance
personnel concerning work performed. Controls and training need to ensure required inspection
personnel verify proper performance of maintenance and that they do not assume or take it on
face value that maintenance personnel performed the maintenance properly. An example from
NTSB accident data shows an aircraft accident resulting from a mechanic using only part of a
procedure to perform the maintenance task, without informing the inspector. Had the mechanic
informed the inspector of exactly what he or she did, the inspector might have realized the
problem and prevented the accident.

4) Evaluate Standards. The manual must include clear acceptance and rejection
standards for required inspections. Standards establish the basis or parameters from which the
person performing the required inspection will determine whether to accept or reject the
maintenance task they are inspecting. The standards give measuring criteria from the means used
to perform the inspection. For example, if torque is used, the standard may be foot-pounds or
inch-pounds. Another example may be indicating pounds per inch to measure pressure, such as
in a cylinder or other pressure vessel.

5) Evaluate Limits. Depending on the standard, the manual must include clear
acceptance and rejection limits. These limits give the exact, or in some cases the maximum
allowable value of the standards being applied. Examples include but are not limited to a specific
torque, pressure, length, thickness, or degree of tolerance for wear or fit.

6) Evaluate Precision Tools, Measuring Devices, and Test Equipment. The

manual must include methods and procedures that call out the necessary precision tools,
measuring devices, and test equipment personnel must use when evaluating maintenance and
alteration standards and limits. This tooling must be environmentally protected and receive
periodic inspection and calibration to an accepted standard. Required inspection acceptance and

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rejection decisions must be precise and accurate and it is the duty of the CAMP operator (per
§§ 91.1425, 121.367, and 135.425) to provide tooling and equipment that is necessary for the
proper performance of maintenance and alterations.

D. Procedures for the Inspection of Work Performed Under Previous Required

Inspection Findings (Buy-Back Procedures).

1) Requirement. Sections 91.1427(b)(4), 121.369(b)(4), and 135.427(b)(4) require

the CAMP operator to include procedures in its manual for the inspection of work performed
under previous required inspection findings (buy-back procedures). The procedures should
include how required inspection personnel will document discrepancies found during the
required inspection. Additionally, the procedures should include how maintenance personnel will
document the work performed to correct discrepancies. Finally, the procedures should include
how required inspection personnel will inspect the work performed to correct discrepancies.

2) Buy-Back Interfaces. Buy-back procedures need to interface with procedures to

ensure the performance of the inspection, as required by §§ 91.1427(b)(6), 121.369(b)(6),
and 135.427(b)(6). Determine if the CAMP operator has procedural requirements to open or note
a new required inspection requirement record for each discrepancy found during a required
inspection. In addition, a buy-back event may be an indicator of a deficiency in the required
inspection system or in the CAMP itself. Therefore, the evaluating ASI should expect to find
buy-back procedures interface and provide reports to the CASS for analysis.

E. Procedures to Ensure the Performance of All Required Inspections.

1) Requirement. Sections 91.1427(b)(6), 121.369(b)(6), and 135.427(b)(6) require

the CAMP operator to have procedures in its manual for ensuring that all required inspections
are performed. To effectively accomplish this, the maintenance program work documents should
clearly identify required inspections and depict when, where, and how they are to be performed.
The CAMP operator may identify such items on its work documents with the abbreviation “RII,”
an asterisk, or any similar method, as long as the instructions clearly explain how required
inspections are to be indicated. It should be noted that required inspection procedures that only
address how to mark work documents when a required inspection is to be performed would not
be considered adequate, unless they include or reference the specific procedures for performing
the inspection.

2) Control and Responsibility. The CAMP operator should specify who is

responsible for completing each step of the required inspection process. The CAMP operator
should incorporate controls in its required inspection process to ensure required inspections are
identified, documented, and completed prior to releasing the aircraft to service, regardless of
whether the CAMP operator, or other persons authorized by the CAMP operator, performed the
inspection. The CAMP operator’s procedures should state who is responsible for identifying and
documenting a required inspection during both scheduled and unscheduled maintenance.

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Methods for identifying a required inspection for a maintenance task can vary, but the CAMP
operator should require, at a minimum:

• Early identification and documentation of the required inspection

requirement, and
• A final review of the paperwork at the completion of work and prior to
releasing the aircraft to service.

F. Instructions (Controls) That Prevent Any Person Who Performs Any Item of
Work From Performing Any Required Inspection of That Work.

1) Requirement. Manual regulations §§ 91.1427(b)(7), 121.369(b)(7),

and 135.427(b)(7) require manual instructions (controls) that prevent noncompliance with the
prescriptive CAMP requirements in §§ 91.1429(c), 121.371(c), and 135.429(c). This includes
any person who provides on-the-job training (OJT) to any person who performs an item of work.

2) Evaluation. A fundamental concept of the required inspection function is that the

person performing the item of work may not perform the required inspection on that item of
work. The regulation recognizes the importance of the independent nature of the required
inspection. As previously stated, it is important that the CAMP operator identify required
inspection requirements as early as possible during the maintenance task, so that everyone is
aware of the requirement, and supervision or management can take steps to assign an inspector
independent of the maintenance task. Regulatory compliance problems are likely to arise during
periods of unscheduled maintenance performed away from a company’s maintenance facility,
due to limited resources. Therefore, it is important that the CAMP operator address these
different situations in its manual and specify its method of control.

G. Countermanding Instructions and Procedures.

1) Requirement. Sections 91.1427(b)(8), 121.369(b)(8), and 135.427(b)(8) require

the CAMP operator to include instructions and procedures in its manual to prevent the reversal
of any decision of an inspector regarding any required inspection by persons other than
supervisory personnel of the inspection unit.

2) Persons with Authority to Countermand a Required Inspection Decision.

Previous paragraphs in this section discussed supervisory personnel and the inspection unit.
Additionally, a person at the level of administrative control that has overall responsibility for the
management of both the required inspection functions and the other maintenance, preventive
maintenance, and alterations functions, may countermand an inspector’s decision. An inspection
unit supervisor has the authority to countermand the decision of the inspector. Moving up the
chain of command, the person with overall responsibility also has authority to countermand
decisions. The person with overall responsibility is the final authority regarding countermanding
a decision. In some organizations, there is only a DOM—and no inspection unit supervisor. The
CAMP operator must establish and identify the responsible person at the level of administrative
control.

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3) Regulatory Intent. The intent of the regulation is to ensure that only certain
responsible and accountable persons, who have the technical training, skills, expertise, and
experience, can countermand decisions. Required inspections are safety controls, and operational
schedule pressures must not influence required inspection performance or acceptance and
rejection decisions. ASIs need to verify that the manual includes the positions (titles) it
authorizes within its organization to countermand an inspector’s decision. Additionally, the
manual should include procedures for documenting the countermand, including signatures and
the basis or reason for the countermand.

4) Countermand Events and CASS. Although regulations recognize countermand

elements in the required inspection process, its use could be an indication of a serious problem or
deficiency in the CAMP operator’s organization. It may be an indication of such things as a poor
safety culture, inadequate scheduling or improper performance of maintenance, inadequate
training or experience of inspection personnel, or deficient required inspection procedures. To
ensure its proper use and effectiveness, the CAMP operator should include the countermand
event in its CASS.

H. Procedures to Ensure Required Inspections That Are Not Completed as a Result

of Shift Changes or Similar Work Interruptions Are Properly Completed Before the
Aircraft is Released to Service.

1) Requirement. Sections 91.1427(b)(9), 121.369(b)(9), and 135.427(b)(9) require

the CAMP operator to include procedures in its manual for ensuring the completion of required
inspections interrupted because of shift changes or similar work interruptions before the release
of the aircraft to service. Whether planned or unplanned, interruptions to required inspections
pose a high risk to the safe operation of the aircraft. To mitigate the risk, the CAMP operator
should provide required inspection personnel with initial and recurrent maintenance resource
management training, including human factor (HF) training.

2) Controls. An effective control for ensuring the completion of required

inspections is the use of work orders, task cards, or work forms designed for the recording of any
interruptions during the required inspection. This form should be part of the CAMP operator’s
work package for the aircraft, and the persons performing work should review the form prior to
releasing the aircraft to service. Another effective control for interruptions is the use of briefings
(hand-downs), both verbal and written. Whatever method used, the CAMP operator should have
a documented process in its manual, and include the necessary instructions and provisions for
other persons to follow when they are performing required inspections for the CAMP operator.

20-6-1-15 PROCEDURES FOR CAMP REQUIRED INSPECTION PERFORMANCE.

ASI performance observations and surveillance consist of onsite observations, desktop
simulations, and record sampling. ASIs will use the manual in conjunction with their knowledge
of the regulations to validate the CAMP operator is performing at high levels to consistently
provide safe, reliable, and airworthy aircraft, and is compliant with the regulations.

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A. Verify CAMP Operator Has a List of Persons Who Are Trained, Qualified, and
Authorized to Conduct Required Inspections.

1) The CAMP operator is responsible to maintain a current listing of persons who

have been trained, qualified, and authorized to conduct required inspections.

2) A CMP may maintain this list. However, the CAMP operator is responsible for
the list and its currency.

3) The list must be made available for inspection by the Administrator upon request,
regardless of who maintains it.

4) The list must identify each person with required inspection authority by name,
occupational title, and the required inspection(s) that they are authorized to perform.

5) Each person with required inspection authority must have written information
from the CAMP operator or the CMP, describing the extent of that person’s responsibilities,
authorities, and inspectional limitations.

B. Verify That Each Person Performing a Required Inspection is Appropriately

Certificated, Properly Trained, Qualified, and Authorized to Do So.

1) Verify personnel on the list meet the competency standards the manual requires.
The CAMP Maintenance and Preventive Maintenance Training Program element must ensure
personnel are competent.

2) Use of personnel not listed, certificated, qualified, trained, or authorized is

indication that there is a lack of supervision and control of required inspections and the
organization is not adequate.

C. Verify That Each Person Performing a Required Inspection is Under the

Supervision and Control of an Inspection Unit (or for Part 91K, the Chief Inspector).

1) Required inspections are safety-centric controls in the performance of

maintenance and alterations. The purpose of organizational supervision and control is to lessen
the threats of performing required inspections improperly. Organizational supervision and
control must have the authority to change personnel behaviors and training and, as necessary,
have a means to correct any required inspection procedure, policy, or shift design.

2) Organizational supervision and control of required inspections is required to

enforce the use of the manual and to ensure its required inspection methods, procedures,
instructions, and standards are effective.

3) The design of the CAMP organization may appear in the manual to be adequate,
but in practice required inspection performance is lacking. Lack of supervision and control is
often subtle and is often a contributing factor to poor required inspection performance.

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4) ASIs are required by §§ 91.1431, 121.373, and 135.431 to notify the CAMP
operator when their assessments find lack of supervision and control are contributing factors to
poor required inspection performance.

5) When the CAMP operator discovers or is notified that a lack of supervision and
control is a contributing factor to poor required inspection performance, §§ 91.1431, 121.373,
and 135.431 require them to correct the deficiency.

D. Verify That a Person Performing a Required Inspection Did Not Perform the
Item of Work That Requires Inspection.

1) Manual regulations §§ 91.1427(b)(7), 121.369(b)(7), and 135.427(b)(7) require

manual instructions (controls) that prevent noncompliance with the prescriptive CAMP
requirements in §§ 91.1429(c), 121.371(c), and 135.429(c).

2) Organizational supervision and control is there to enforce the use of the manual
and to ensure its required inspection methods, procedures, instructions, and standards are
effective.

3) ASIs are required by §§ 91.1431, 121.373, and 135.431 to notify the CAMP
operator when their assessments find lack of supervision and control are contributing factors to
poor required inspection performance.

4) When the CAMP operator discovers or is notified that a lack of supervision and
control is a contributing factor to poor RII performance, §§ 91.1431, 121.373, and 135.431
require them to correct the deficiency.

E. Confirm Through Observation That Personnel Follow the Manual to Perform

Required Inspections.

1) Observe personnel following the manual method of performing required

inspections and assess if this method is effective.

2) Sample required inspection records and verify a person designated by

occupational title did each required inspection, and verify that that person had been authorized to
perform that specific required inspection.

3) Sample required inspection records and verify the procedures that personnel
documented and used to perform the required inspection are included in the manual. Determine
if these procedures are effective.

4) Sample required inspection records and verify documentation that shows items
requiring inspection conform to the standards and limits established in the manual.

5) Verify personnel used only precision tools, measuring devices, and test equipment
that the manual requires to make required inspection decisions.

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6) Sample records and verify precision tools, measuring devices, and test equipment
receive periodic inspection and calibration.

7) Sample RII records to verify that manual procedures for reinspection of work
performed under previous required inspection findings (buy-back procedures) were followed and
are effective.

8) Sample RII records and verify the procedures to ensure the performance of all
required inspections are effective. Verify procedures are clear and call out each required
inspection and that the procedures require a record to substantiate accomplishment of each
required inspection prior to the aircraft’s return to service.

9) Through performance observations or record reviews, verify that a person

performing a required inspection did not perform the item of work that requires inspection.
Manual regulations §§ 91.1427(b)(7), 121.369(b)(7), and 135.427(b)(7) require manual
instructions (controls) that prevent noncompliance with the prescriptive CAMP requirements in
§§ 91.1429(c), 121.371(c), and 135.429(c).

10) Have discussions with required inspection personnel and inspection unit
supervisory personnel. Determine if persons other than supervisory personnel of the inspection
unit, or a person at the level of administrative control that has overall responsibility for the
management of both the required inspection functions and the other maintenance, preventive
maintenance, or alterations functions, countermanded any decision of an inspector regarding any
required inspection.

11) By observation or simulations, determine the effectiveness of manual procedures

that ensure all maintenance (including required inspections), preventive maintenance, or
alterations that are not completed because of work interruptions are properly completed before
the aircraft is released to service.

20-6-1-17 TASK OUTCOMES.

A. Complete the Task. Follow Volume 10 SAS Guidance for Module 4 for Data
Collection and Data Reporting.

B. Conduct Debriefing. Brief the CAMP operator on the inspection results. Discuss all
deficiencies, CAMP operator corrective actions, and FAA actions. The ASI can find instructions
for conducting briefings in Volume 1, Chapter 3, Section 1. ASIs are required by §§ 91.1431,
121.373, and 135.431 to notify the CAMP operator when they find required inspection
procedures and standards are not adequate. When the CAMP operator discovers or is notified
that required inspection procedures and standards are not adequate, §§ 91.1431, 121.373,
and 135.431 require them to correct the deficiency.

C. Compliance and Enforcement Action. If safety issues and/or regulatory

noncompliance are identified, follow the process contained in Volume 14, Chapter 1, Section 2
to determine the appropriate FAA compliance or enforcement action.

D. Document the Task. Update configuration data, if required.

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20-6-1-19 FUTURE ACTIVITIES. For parts 121 and 135, follow Volume 10 guidance to
plan future risk-based surveillance in SAS. FAA Order 1800.56, National Flight Standards Work
Program Guidelines, Appendix A, paragraph 7.4, contains the part 91K CAMP surveillance
requirements.

20-6-1-21 through 20-6-1-35 RESERVED.

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