Steve Baidwan

Dear Sir / Madam The AD 90-25-05 issued stated -- Within one year after December 31, 1990 (the effective date of AD 90-25-05), revise the FAA-approved maintenance program to include the corrosion control program specified in Boeing Document Number D6- 36022, "Aging Airplane Corrosion Prevention and Control Program, Model 747,'' Revision A, dated July 28, 1989, (hereinafter referred to as "the Document''). This reads that the AD is limited to ALL Boeing 747 being maintained on FAA Aprpoved Maintenance Program. All other foreign programs approved by other CAA are excepted and do not have to follow this AD. I have noted that while importing B747s from some foreign Operators that some times there are significant differences from previous Operator CPCP program to that of the D6-36022 program. There could be interval differences, task cards not specifying the basic task requirements, requirements to re-apply BMS3-23, 3-26, 3-29 as applicable if the areas were cleaned or not applying the CIC compound as it should be at all required areas, some task cards do not have cautions not to spray the CIC at pulleys, cannon plugs etc. Some Operator will use the I plus R as implementation age which for FAA Ops spec entry is not acceptable automatically but pending a review of Operator operation area, fleet size, humiditity levels at based areas etc. Some operator might choose the CPCP as a sampling program within its fleet. Since these cases do not meet the CPCP AD 100%, the import process overlooks this AD as it is technically applicable to only FAA Approved Maintenance Program. In my view the word FAA should be removed from all such AD;s to improve Flight safety and have all Operators held responsible to same standard to maintain the required structural safety and integrity. Once these aircraft are imorted to US, these could fly on ferry permits for internal movement for painting or storage or to a MRO for C check and techncially they are flying with a AD not in full compliance. SSID AD should also be looked at in same manner. The FAA DAR are posed with this question that at time of issuance of the US C of A the aircraft has no maintenance program therefore all AD requiring and mandated by FAA Approved maintenance program are program bridging issues. In my view at time of issuance of a US C of A it should be mandated that there be a log entry made to select the interim program and that can be the Boeing MPD as allowd by FAR 91.409.F,except that the bridging from the previous operator to next operator Maintenance Program may be delayed prior to next Commercial Flight. This will give relief to US Aircraft Lessor;s not to bridge the programs to MPD while the aircraft is in transistion to another country and another program. Under this suggested concept a FAA Approved Maintenance Program is immediately selected which needs integration of the AD like 90-25-05 and other similar AD which at the moment are limited to FAA Approved Maintenance program and therfore require the FAA DAR to seek 100% compliance to the D6- 36022 and other AD standards as applcable. Some third world Countries may view the US C of A and US Export C of A as an compliacne to these AD:s. If the above proposal is not acceptable then the US C of A and US Export C of A should list an Exception that the following AD previous compliance should be reviewed and to ensure it meets the importing country requirements (which in most cases rely on county of manufacture requirements). Regards Steve Baidwan Airworthiness Inspector Global Aviation www.Globalaviationconsulting.com 91.409.f does allow immediately at issuance of C of A for one to make an entry in log book that the Aircraft under new registry will follow Boeing MPD program as allowed by FAR 91.409.f.3. f) Selection of inspection program under paragraph (e) of this section. The registered owner or operator of each airplane or turbine-powered rotorcraft described in paragraph (e) of this section must select, identify in the aircraft maintenance records, and use one of the following programs for the inspection of the aircraft: (1) A continuous airworthiness inspection program that is part of a continuous airworthiness maintenance program currently in use by a person holding an air carrier operating certificate or an operating certificate issued under part 121 or 135 of this chapter and operating that make and model aircraft under part 121 of this chapter or operating that make and model under part 135 of this chapter and maintaining it under ?135.411(a)(2) of this chapter. (2) An approved aircraft inspection program approved under ?135.419 of this chapter and currently in use by a person holding an operating certificate issued under part 135 of this chapter. (3) A current inspection program recommended by the manufacturer. (4) Any other inspection program established by the registered owner or operator of that airplane or turbine-powered rotorcraft and approved by the Administrator under paragraph (g) of this section. However, the Administrator may require revision of this inspection program in accordance with the provisions of ?91.415.