Kevin Miller

The rule is not clear if this includes off-wing engine maintenance contract facilities. When the FAA implemented the “Essential Maintenance” guidance, a few years back, it excludes off-wing engine maintenance providers, based on the non-application of “Required Inspection Items” for this type maintenance. The misconception that “Essential maintenance that could result in a failure, malfunction, or defect endangering the safe operation of an aircraft if not performed properly or if improper materials are used;” does not apply to engines because multi-engine aircraft are capable of providing a safe landing, misses the following assumptions: 1. That these maintenance providers could perform improper maintenance or use of improper materials on continued bases, resulting in both engines affected. 2. Should a single event occur where a failure results in uncontained debris penetrating the fuselage and contacting crew, passengers, or vital systems, it could cause death or catastrophic damage to the aircraft. [Containment certification is based on the proper use of materials and maintenance.]