Raymond Benischeck

My comments are related to Question 1- Continuing Obligation and Question 2- Additional Actions of Docket FAA-2010-1167. As an aviation maintenance provider, I am often faced with the confusing and challenging interpretation of ADs that may include follow up actions, be they recurring inspections, mandatory retirement intervals or prohibition of the installation of certain parts. Per the requirements of FAR 91.417 (a)(2)(v) each owner or operator is required to keep a record of among other things, the time and date of ADs with recurring requirements. Some of the terms used to denote such ADs are Repetitively, Thereafter, Reinspect, Recurring, Repeat and Following (as in an action or event). No standard term is utilized in the publication of Recurring ADs. ADs as they are currently written give us categories for Effective date, Affected ADs, Applicability, Unsafe Condition, Compliance, AMOCs, Related Information and Material Incorporated by Reference. Nowhere does the AD specifically state in consistent language whether the AD has follow up requirements that must, by FAR, be included in the aircraft Maintenance Records. I respectfully request you consider adding a category that specifically states that the AD carries Continuing Obligation (Question 1) or Additional Actions (Question 2). Standard Terminology would eliminate one source of confusion when complying with Recurring Airworthiness Directives.