Airworthiness Directive Compliance: Build a Current-Status Record

Airworthiness-directive compliance is not established by an annual-inspection sticker or a search for the aircraft model alone. It is established by the exact directive, its applicability language, the aircraft and installed-product configuration, the required action, and a record showing where the aircraft stands now.

The FAA says owners and operators are responsible for complying with every AD that applies to their product. Operating a product that does not meet an applicable AD violates 14 CFR 39.7. Maintenance personnel have their own responsibilities, but an owner cannot transfer the underlying operating responsibility to a spreadsheet or a shop relationship.

Build the configuration record first

An AD may apply to an airframe, engine, propeller or appliance. Applicability can turn on model, serial number, part number, modification status or the presence of a particular component.

Start with a dated configuration record containing:

• aircraft make, model, serial number and registration;
• engine and propeller make, model and serial numbers;
• installed appliances and safety-critical components identified by part or model number where relevant;
• supplemental type certificates and major alterations;
• component changes that may have introduced or removed an affected part; and
• the date and aircraft time at which the configuration was checked.

This does not replace maintenance records. It makes the AD search reproducible and gives the person reviewing applicability something more precise than an aircraft nickname.

Search the current directive, not a remembered summary

The FAA's Airworthiness Directives page routes users to the Dynamic Regulatory System for current AD research. Search each product family in the configuration record, then read the directive itself.

For every possible match, capture:

1. the AD number and amendment or revision status;
2. the exact applicability paragraph;
3. the unsafe condition addressed;
4. the compliance time or trigger;
5. whether the action repeats;
6. any terminating action; and
7. any alternative method of compliance already approved for the aircraft.

A model-name match is not an applicability decision. Neither is the absence of a result from one commercial tracker. Record why the directive applies or does not apply to the actual product.

Separate service information from the legal requirement

An AD can incorporate manufacturer service information by reference. When it does, the directive establishes the mandatory action and the incorporated material supplies part of the method.

Do not reduce this to "service bulletins are optional." A service document may be required by an AD, an approved maintenance or inspection program, or another operating requirement. The clean record identifies the authority that makes the action required instead of treating every manufacturer document the same way.

Record current status in a form another reviewer can audit

Section 91.417 requires the owner or operator to retain a record of the current status of applicable ADs. The regulation calls for the method of compliance, AD number and revision date, and, when the AD repeats, the time and date when the next action is required.

A usable status row therefore contains:

Field	What to record
Product	Airframe, engine, propeller or appliance affected
Applicability	The configuration fact that makes the AD applicable or not applicable
Compliance method	Inspection, replacement, modification, limitation or approved alternative
Last action	Date, aircraft or component time, and maintenance-record reference
Repetition	Next due date, time or other trigger
Terminating action	Whether completed, and the supporting record
Evidence	Logbook entry, work order, Form 337, part record or other retained document

"Complied with" is not enough if the next reviewer cannot determine what was done, when it was done or when it is due again.

When the record shows a gap

First, read the exact directive and establish whether the compliance time has passed. Do not assume every gap has the same operational consequence.

Then:

• stop treating the aircraft as dispatchable until an appropriately authorized person has assessed the directive and configuration;
• locate the underlying log entries, component records and alteration documents;
• determine whether the required action was completed but recorded poorly, or was not completed;
• use the directive's stated method, or an FAA-approved alternative method of compliance where applicable;
• make the required maintenance entry and update the current-status record; and
• review adjacent products and recurring intervals so the same records failure is not repeated.

Do not assume a phone call creates an extension. If movement is necessary, check the directive and the FAA process for any specifically authorized special-flight-permit path before acting.

The practical standard

A defensible AD file answers four questions without guesswork: what is installed, which current directives apply, what action established compliance, and what is due next. That is a much stronger operating control than a generic annual checklist.

Sources

• FAA: Airworthiness Directives responsibilities
• FAA: Airworthiness Directives
• eCFR: 14 CFR 39.7 - What is the legal effect of failing to comply with an AD?
• eCFR: 14 CFR 91.403 - General maintenance responsibility
• eCFR: 14 CFR 91.417 - Maintenance records
• FAA: AC 39-7D, Airworthiness Directives