FAA Eliminates RVSM Maintenance Program Requirement

Effective August 19, 2016, operators seeking RVSM approval no longer need to submit an RVSM Maintenance Program. The FAA has just released its revision to AC 91-85A and the RVSM Job Aid.

What IS changing:
Removing the Maintenance Program approval component from RVSM applications should significantly decrease inspector review of new RVSM applications. In addition, “pre-application meetings” are now optional. An operator may request one, but inspectors should not require it.

What is NOT changing:
The rule change does not affect existing FAA-approved RVSM Maintenance Programs and FAA-accepted Operations Programs. Operators must continue to comply with and update such programs. New RVSM approvals still require an application that includes the following components:
• RVSM Compliant Aircraft
• RVSM Knowledgeable Pilots
• Aircraft RVSM Required Equipment List
• RVSM Height Monitoring Plan
• RVSM Operations Program

Operators must also still submit documentation to their FSDO when information affecting their LOAs change (such as replacement or upgraded RVSM component part numbers, the name of the RVSM Responsible Person, a business or mailing address change, etc.)

This change does not affect the operator’s responsibility for complying with recurrent maintenance as identified in the manufacturer’s maintenance manual (AMM) or the STC holder’s Instructions for Continued Airworthiness (ICA). The aircraft RVSM systems must be maintained in accordance with the applicable document.

Part 91 RVSM applications are still the FAA’s lowest priority. So there will likely still be a wide range of operator experiences in FAA responsiveness to new RVSM applications.

International approvals such as NAT HLA, RNP, etc are not affected by this change.

What is uncertain:
AC 91-85A contains vague language which opens the door to variations and inconsistencies between FAA inspectors regarding the new RVSM process. For example, the AC requires submitting “complete documentation of an RVSM-compliant program…” without explaining what constitutes “complete.” The AC also allows a FSDO to request whatever information they require “…to efficiently process the [RVSM] request.” The FAA no longer needs to review an operator’s RVSM Operations Program when considering a new RVSM application IF previously it has been “thoroughly reviewed” by the FAA and it completely accounts for RVSM operations of the new aircraft. Unfortunately there are no examples or standards for knowing if an operations program had been thoroughly FAA reviewed in the past, or completely covers operational procedures related to RVSM on a new aircraft. It’s possible some of these inconsistencies will be addressed in the upcoming revision to FAA Order 8900.1 (FSIMS) – the guidance the inspectors use to comply with a regulatory change.

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