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Minimum Equipment List/Permissible

Unserviceability Procedures Manual

Date August 2017


Approval Tier Three
Approver Manager Airworthiness and Engineering Branch
Sponsor Manager Engineering Services
Review Date August 2019
Minimum Equipment List/Permissible
Unserviceability Procedures Manual

© Civil Aviation Safety Authority


All material presented in this Guidance document is provided under a Creative Commons Attribution
4.0 International licence, with the exception of the Commonwealth Coat of Arms (the terms of use for
the Coat of Arms are available from the It's an Honour website). The details of the relevant licence
conditions are available on the Creative Commons website, as is the full legal code for the CC BY 4.0
license.

Attribution
Material obtained from this document is to be attributed to CASA as:
© Civil Aviation Safety Authority 2017.

This document becomes an uncontrolled document when printed. Refer to


<www.casa.gov.au/scripts/nc.dll?WCMS:STANDARD::pc=PC_91264 > for current version.
This document contains guidance material intended to assist CASA officers, delegates and the aviation
industry in understanding the operation of the aviation legislation. However, you should not rely on this
document as a legal reference. Refer to the civil aviation legislation including the Civil Aviation Act 1988
(Cth), its related regulations and any other legislative instruments—to ascertain the requirements of,
and the obligations imposed by or under, the law.

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Preface
As a Commonwealth government authority, CASA must ensure that the decisions we make,
and the processes by which we make them, are effective, efficient, fair, timely, transparent,
properly documented and otherwise comply with the requirements of the law. At the same
time, we are committed to ensuring that all of our actions are consistent with the principles
reflected in our Regulatory Philosophy.
Most of the regulatory decisions CASA makes are such that conformity with authoritative
policy and established procedures will lead to the achievement of these outcomes.
Frequently, however, CASA decision-makers will encounter situations in which the strict
application of policy may not be appropriate. In such cases, striking a proper balance
between the need for consistency and a corresponding need for flexibility, the responsible
exercise of discretion is required.
In conjunction with a clear understanding of the considerations mentioned above, and a
thorough knowledge of the relevant provisions of the civil aviation legislation, adherence to the
procedures described in this manual will help to guide and inform the decisions you make,
with a view to better ensuring the achievement of optimal outcomes in the interest of safety
and fairness alike.

Shane Carmody
Chief Executive Officer and
Director of Aviation Safety

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Table of Contents

Preface ....................................................................................................................................................... 3
Table of Contents ....................................................................................................................................... 4
Glossary ..................................................................................................................................................... 6
Acronyms and abbreviations .................................................................................................................. 6
Definitions............................................................................................................................................... 7
Revision history .......................................................................................................................................... 8
1 Introduction......................................................................................................................................... 9
1.1 Purpose of this Manual .............................................................................................................. 9
1.2 Scope of this Manual .................................................................................................................. 9
1.3 Background ................................................................................................................................ 9
1.3.1 Regulatory basis................................................................................................................. 9
1.3.2 Airworthiness and operational requirements .................................................................... 10
1.3.3 The purpose of the Master Minimum Equipment List ...................................................... 10
1.3.4 The purpose of the Minimum Equipment List .................................................................. 10
1.3.5 Approval for specific defect or damage as a permissible unserviceability ....................... 10
1.3.6 Configuration Deviation List ............................................................................................. 10
1.4 Responsibility for MEL/PU Policy and Approval Procedures ................................................... 11
1.4.1 Safety Assurance Branch ................................................................................................. 11
1.4.2 Airworthiness & Engineering Branch ............................................................................... 12
1.5 MEL Review Group .................................................................................................................. 12
1.5.1 Function of an MEL Review Group .................................................................................. 12
1.5.2 Duties of the MEL Review Group Coordinator ................................................................. 12
2 MEL approval/amendment procedures ............................................................................................ 13
2.1 Introduction............................................................................................................................... 13
2.1.1 Operators document ........................................................................................................ 13
2.1.2 Purpose ............................................................................................................................ 13
2.1.3 Delegate ........................................................................................................................... 13
2.1.4 Approval fee ..................................................................................................................... 13
2.1.5 Mandatory amendments .................................................................................................. 13
2.2 MEL format ............................................................................................................................... 14
2.2.1 MEL contents ................................................................................................................... 14
2.3 Initial enquiries regarding approval/amendment of MELs ........................................................ 15
2.3.1 Provision of initial information .......................................................................................... 15
2.4 Procedures ............................................................................................................................... 16
2.4.1 Administrative procedures ................................................................................................ 16

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2.4.2 Assessing an MEL............................................................................................................ 18


2.4.3 Repair Intervals ................................................................................................................ 23
2.4.4 Issue of MEL Approval ..................................................................................................... 24
2.4.5 Assessing Amendments to MELs .................................................................................... 28
2.5 MEL administration .................................................................................................................. 31
2.5.1 Operator responsibility ..................................................................................................... 31
2.5.2 CASA Responsibility ........................................................................................................ 31
2.5.3 Office Record Retention ................................................................................................... 33
3 Permissible Unserviceability Approval Process ............................................................................... 34
3.1 Introduction to the PU Approval Process ................................................................................. 34
3.1.1 Reasons for a PU ............................................................................................................. 34
3.1.2 PU versus Special Flight Permit....................................................................................... 34
3.1.3 Limitations and Conditions ............................................................................................... 36
3.2 Initial Enquiries Regarding Approval of a PU ........................................................................... 37
3.2.1 Handling Enquiries ........................................................................................................... 37
3.2.2 Provision of Initial Information .......................................................................................... 37
3.3 PU approval procedure ............................................................................................................ 38
3.3.1 Scope of this Procedure ................................................................................................... 38
3.3.2 Staff Responsible ............................................................................................................. 38
3.3.3 PU Approval Procedure ................................................................................................... 38
3.3.4 Criteria for Assessment for Certification and Operational Standards .............................. 39
3.3.5 Issue of PU Approval ....................................................................................................... 41

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Glossary
Acronyms and abbreviations
Acronym / abbreviation Description

AFM Aircraft Flight Manual


AIP Aeronautical Information Publication
AD Airworthiness Directive
ASTC Australian Supplemental Type Certificate
ATA Air Transportation Association
AWE Airworthiness Engineer
AWI Airworthiness Inspector
CoR Certificate of Registration
CAA Civil Aviation Act 1988
CAO Civil Aviation Orders
CAR Civil Aviation Regulations 1988
CASA Civil Aviation Safety Authority
CASR Civil Aviation Safety Regulation 1998
CDL Configuration Deviation List
DDG Dispatch Deviation Guide
ETOPS Extended Range Twin Engine Operations
FOI Flying Operations Inspector
iaw In accordance with
LAME Licensed Aircraft Maintenance Engineer
LEP List of Effective Pages
M/R Maintenance Release
MCM Maintenance Control Manual
MEL Minimum Equipment List
MMEL Master Minimum Equipment List
NAA National Aviation Authority
PIC Pilot-in-Command
PU Permissible Unserviceability
PUS Permissible Unserviceability Schedule
RPT Regular Public Transport
STC Supplemental Type Certificate

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Acronym / abbreviation Description

TAC Type Acceptance Certificate


TC Type Certificate
TCDS Type Certificate Data Sheet
VMC Visual Meteorological Conditions

Definitions
Term Definition

As required by regulations The listed item of equipment is subject to certain provisions (restrictive
or permissive) expressed in the Civil Aviation Regulations 1988
(CAR), Civil Aviation Safety Regulations 1998 (CASR) or Civil Aviation
Orders.
Deactivated and/or secured Operation of the item of equipment or instrument is prevented so that
it is unusable by the pilot/crew. (An acceptable method of deactivating
and/or securing an item of equipment or instrument must be
established by the operator for inclusion in the MEL.)
Inoperative A system and/or component has malfunctioned to the extent that it
does not accomplish its intended purpose and/or is not consistently
functioning normally within its approved operating limits or tolerances.
Item of equipment Includes all instruments and equipment installed in the aircraft, and all
aircraft systems.
Acceptable Master Minimum An MMEL either approved by CASA or National Aviation Authority
Equipment List (MMEL) (NAA) of the state of design as part of the issue of the type
acceptance certificate (TAC) for the aircraft.
Minimum Equipment List A document approved by CASA that contains the conditions under
(MEL) which a specified aircraft may operate with particular items of
equipment inoperative at the time of dispatch.
Operator A person, organisation, or enterprise engaged in, or offering to engage
in, an aircraft operation.
Time of dispatch The time the aircraft engines are started or the commencement of
pushback from the terminal for the purposes of the flight.
Note however that major airline manufacturers define the point of
dispatch differently and when constructing an operator MEL the
dispatch point should align with the MMEL reference.

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Revision history
Amendments/revisions of this Manual are recorded below in order of most recent first.

Version No. Date Parts/Sections Details

2.0 August 2017 All Updated into CASA approved


template.
Full review of content
1.3 November 2010 Cover Updated TOC, Preface and
TOC List of Effective Pages (LEP)
1.2 December 2004 Various • Introduction to MEL/PU
Approval Procedures
• MEL
Approval/Amendment
Procedures
• Permissible
Unserviceability (PU)
Approval Process
1.2 October 2002 All • Branch details
updated.
• Applicability of MMEL
Flowchart added
• Provision of initial
information updated
1.0 June 2001 All First issue

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1 Introduction
1.1 Purpose of this Manual
This Manual provides guidance to CASA staff on the procedures to be followed for the
approval of a defect in, or damage to, an aircraft, as a permissible unserviceability (PU) under
regulation 37 of CAR - accordingly, it does not cover Part 42 Regular Public Transport (RPT)
aircraft.
1.2 Scope of this Manual
This manual sets out the procedures for the approval of:
• a MEL for an operator’s aircraft, and amendments made to it
• PUs for an aircraft on a one-off basis.
In developing the manual, the requirements, recommendations and procedures of the
International Civil Aviation Organisation (ICAO), the European Joint Aviation Authorities (JAA),
the U.S. Federal Aviation Administration (FAA), the UK Civil Aviation Authority (CAA UK) and
Transport Canada (TC) were considered and adopted where they were consistent with the
Australian Civil Aviation Legislation.
The manual is part of the CASA document set. It includes flow charts, letters and forms to aid
CASA officers in the performance of an assessment for approval of MELs and PUs.
The manual consists of:
• chapter 1 (this chapter)—a general overview of the process
• chapter 2—guidance and procedures for developing and approving an MEL together
with information on its use during operations
• chapter 3—procedures for the approval of an individual defect or damage as a PU.
By adhering to the manual’s procedures, a national standard and unified approach consistent
with regulatory requirements will be created and maintained when approving MELs and PUs.
1.3 Background
1.3.1 Regulatory basis
1. CAR 37(1) states that CASA may approve a defect in, or damage to, an Australian
aircraft as a PU. Under CAR 37(2), CASA may direct that the use of an aircraft with a
PU is subject to conditions as set out in the direction.
2. CAR 42L requires that if PUs have been approved for an aircraft in the form of an
MEL, the MEL must be included in the system of maintenance for the aircraft.
3. CAO 20.18 requires that all instruments and equipment fitted to RPT or charter aircraft
to be serviceable unless otherwise approved by CASA. An approved MEL/PU satisfies
this requirement. CAO 20.18 also directs an operator of RPT aircraft to have an
approved MEL for each aircraft operated.
4. It is important to note that Registered Operator of an aircraft that is not utilised in RPT
operations, or aircraft for which an approved system of maintenance is not required,
may also elect to have an MEL for their aircraft.

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1.3.2 Airworthiness and operational requirements


Airworthiness and operational requirements, including the aircraft type design approval
requirements, require that every item of equipment installed in the aircraft must be operational
at the beginning of a flight.
However, because of the various levels of redundancy designed into aircraft, under certain
conditions an acceptable level of safety can be maintained with specific items of equipment
inoperative for a limited period of time until repairs can be made using an MEL/PU.
1.3.3 The purpose of the Master Minimum Equipment List
A MMEL is a document created for the purpose of regulating the continued operation of an
aircraft type while certain items of equipment are inoperative. Normally the MMEL is
developed by the aircraft manufacturer and is approved / accepted by the appropriate NAA
responsible for the type certification of the aircraft.
The MMEL is a list of items of equipment that may be temporarily inoperative, subject to
certain conditions and limitations, while still maintaining the level of safety intended in the
design standards. The MMEL does not take into account the operating circumstances of
individual operators of the type concerned and therefore it cannot, in itself, be regarded as
providing operational permission. The MMEL is, however, the basis for the development of an
individual operator's MEL.
1.3.4 The purpose of the Minimum Equipment List
An MEL is a document that allows for the operation of an individual aircraft by a specific
operator under specified conditions, with particular item(s) of equipment inoperative at the
time of dispatch for an intended flight.
Note: This does not imply that the aircraft may be operated with an item removed unless the
approved MEL explicitly allows such removal.

An MEL, which is based on the MMEL, consists of an approved list of the specific inoperative
equipment for a particular make and model of aircraft by serial number and registration mark
(eg, BE-200, VH-XXX). Its use is described in the associated procedures contained in an
operator’s maintenance control manual and/or operations manual, or other appropriately
documented procedures (for class B aircraft).
An MEL is derived from the MMEL and is normally not less restrictive than the corresponding
MMEL, except where regulatory requirements permit. An operator’s MEL must take into
account the aircraft configuration, type of operation and operating environment.
An approved MEL for an aircraft is a non-transferable document. If an aircraft moves from one
operator to another, the new operator cannot automatically use the previously approved MEL.
1.3.5 Approval for specific defect or damage as a permissible unserviceability
Registered operators not having an approved MEL for their aircraft may also request approval
from CASA for operations with a specific defect or damage in the aircraft as a PU. Also,
under certain circumstances, operators of aircraft with an approved MEL may request
approval from CASA for PUs that are not included in the MEL, as they occur.
1.3.6 Configuration Deviation List
A Configuration Deviation List (CDL), or its equivalent, is not part of the MMEL/MEL and is not
dealt with in this manual. CDLs where published, are approved as part of the Aircraft Flight

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Manual (AFM). A CDL may be included as a separate section to the MEL, but is not approved
under CAR 37.
1.4 Responsibility for MEL/PU Policy and Approval Procedures
1.4.1 Safety Assurance Branch
The responsibilities of CASA staff with respect to MEL/PUs are as follows:
Region Office
• upon request from the Team Leader, coordinate with other Region Offices if
appropriately qualified/experienced personnel are not available within their area.
Certificate Team Manager
• nominate an Airworthiness Inspector (AWI) as coordinator for the MEL Review Group
• nominate review group members in consultation with other disciplines
• oversee the progress of the MEL Review Group
• approve MEL/PUs, as required.
MEL Review Group Coordinator
• coordinate the MEL/PU assessment and approval process with all relevant technical
disciplines
• liaise with the applicant on matters related to MELs and PUs
• provide advice on maintenance related matters concerning the approval of MELs and
PUs
• evaluate and approve (within the limitations of their delegation) PUs and MELs as
required.
Airworthiness Engineer (where necessary)
• as a member of the MEL Review Group, evaluate an applicant’s MEL submission and
make recommendations on those items requiring engineering assessment
• provide advice on engineering related matters concerning the approval of MELs and
PUs.
Flying Operations Inspector
• as a member of the MEL Review Group, evaluate an applicant’s MEL submission and
make recommendations
• provide advice on flying operations related matters concerning the approval of MELs
and PUs.
Cabin Safety Specialist (where necessary)
• as a member of the MEL Review Group, evaluate an applicant’s MEL submission and
make recommendations
• provide advice on cabin safety related matters concerning the approval of MELs and
PUs.

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1.4.2 Airworthiness & Engineering Branch


The responsibilities of Airworthiness & Engineering Branch staff with respect to MEL/PUs are
to provide specialist advice on matters related to the approval and use of MMELs, MELs and
PUs, when required.
1.5 MEL Review Group
1.5.1 Function of an MEL Review Group
Purpose
An MEL Review Group is formed when an operator submits an MEL for approval.
The purpose of forming such a group is to:
• provide adequate management of the approval process
• ensure proper, and formalised, coordination between airworthiness, operations and
other relevant disciplines.
Responsibilities of an MEL Review Group
The MEL group will assess the submitted MEL in accordance with this procedures manual
using the applicable MMEL as a baseline document. The level of assessment required will
depend on how closely the contents of the MEL reflect the master document and the suitability
of manufacturer’s supplied documentation (eg, Dispatch Deviation Guide or similar). In all
cases, assessment must be carried out on the adequacy of O and M procedures. It is
essential for the group to ensure that the proposed MEL does not allow operation in
contravention of the regulatory requirements.
At the discretion of the Team Leader, revisions to an approved MEL may require a meeting of
the MEL Review Group. This may be necessary when items within the submission are not
contained in the applicable MMEL for the aircraft MEL under review.
Reporting Relationship
The MEL Review Group reports, via the coordinator, to the Delegate.
1.5.2 Duties of the MEL Review Group Coordinator
The coordinator is responsible for the management of the overall MEL assessment and
approval process and must:
• chair MEL Review Group meetings
• provide the formal contact between CASA and the applicant on MEL matters
• refer any dispute between individual team members, or between the team and the
applicant’s staff to the delegate
• coordinate the work done by the MEL Review Group
• ensure the group reviews the MEL submitted by the applicant, in accordance with the
procedures in this manual
• keep the applicant informed if any major differences occur, or are likely to occur,
between estimated and actual approval cost
• ensure a record of any decisions taken and the reasons for them are retained on file
• coordinate approval and administrative functions.

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2 MEL approval/amendment procedures


2.1 Introduction
2.1.1 Operators document
An MEL is an approved list that provides for the operation of an aircraft with particular
equipment inoperative, subject to specified conditions and procedures. The MEL is
customised to the operator’s specific aircraft, keeping in mind the installed equipment and the
type of operation, and may be dependent upon:
• operating environment
• route structure
• geographic location
• number of airports where spares and maintenance capability etc are available.
Note: For these reasons an MMEL cannot be approved for use as an MEL by an operator.

2.1.2 Purpose
An MEL is a document that allows for the operation of a specific aircraft under specified
conditions, with particular item(s) of equipment inoperative at the time of dispatch for the
intended flight.
The MEL is a document used by an operator to:
• define the process for managing PU
• identify items of equipment that may be unserviceable and any associated conditions
• define maintenance procedures necessary to maintain the required level of safety and
procedures necessary to deactivate and/or secure any inoperative items of equipment
• define operational procedures necessary to deal with inoperative items of equipment.
2.1.3 Delegate
Approval of the aircraft MEL rests with the appropriate airworthiness delegate under CAR 37.
Format
The CAA, CARs or CAOs do not stipulate any specific format and/or content for an MEL.
However, the format provided within CAAP 37-1 would aid the assessment of the MEL, and it
is also an internationally accepted format.
2.1.4 Approval fee
Approval of an MEL or an amendment to an MEL attracts a fee. The total chargeable fee is
based on the actual working hours involved in assessing the MEL, at the hourly rate published
in the Civil Aviation (Fees) Regulations 1995, as amended from time to time.
2.1.5 Mandatory amendments
Mandatory amendment of an MEL is required when:
• the applicable MMEL is amended so as to become more restrictive
• any published O and M procedures utilised in the MEL are amended

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• when new airworthiness or operational items of equipment or system standard is


introduced
• the amendment is required by CASA as a result of an in-service experience
• Airworthiness Directives (ADs) issued affect MEL item(s)
• legislative changes affecting MELs are published
• aircraft modifications are embodied that require MEL amendment.
2.2 MEL format
2.2.1 MEL contents
A sample page of an MEL is shown in CAAP 37-1.

The MEL must include:


• a LEP
• a revision control page
• a Table of Contents
• a preamble which meets the intent of the CASA Minimum Equipment List Preamble—
see CAAP 37-1
• Notes and Definitions—see CAAP 37-1
• a section for each aircraft Air Transportation Association (ATA) Chapter and the items
covered within those chapters
• the appropriate operations and maintenance (O & ’M’) procedures
• the appropriate repair intervals (stated in the MEL Preamble).
List of Effective Pages
The LEP is used to ensure that each MEL is up to date. It must list the date of the last revision
for each page.
The date and revision status of each page of the MEL must correspond with that shown on the
LEP.
Revision Control Page
The revision control page is a record of revisions that have been carried out in the MEL and
should contain the revision date and the signature of the person who carried out the revision.
This page indicates the current revision status of the MEL.
Table of Contents
The Table of Contents page lists the section for each aircraft system, normally using the ATA
numbering system, as found in the MMEL.
Chapter and Page Numbering
It is preferable to use the ATA numbering system and sequence numbers as given in the
MMEL. Number pages with the ATA system number followed by the page number for that
system (eg, the page following 27-2-1 would be 27-2-2).
The MEL page format should be similar to the MMEL or as shown in CAAP 37-1.

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The Minimum Equipment List Preamble


The purpose of the MEL Preamble is to provide general direction to company personnel on
the philosophy and use of the MEL.
CASA has published an MEL Preamble, which is the template for use by an operator. See
CAAP 37-1.
Operators may choose to develop their own preamble, but as a minimum, it must meet the
intent of the information contained in the CASA version.
Notes and Definitions
Notes and definitions are required to allow the user to interpret the MEL properly. Notes and
definitions utilised in the MMEL are to be used in the MEL where applicable, together with any
additional ones that may be necessary to customise the document for an operator’s particular
requirements. Notes and definitions not applicable to a particular aircraft should not be
included in the operator’s MEL. The CASA Sample MEL Notes and Definitions (CAAP 37-1)
take precedence over the MMEL Notes and Definitions where inconsistency occurs.
2.3 Initial enquiries regarding approval/amendment of MELs
2.3.1 Provision of initial information
When an operator expresses the intent to operate an aircraft using an MEL, the delegate will
provide the operator with the following information, as necessary:
1. Application requirements for the approval of an MEL. An operator submitting an MEL
for approval must provide its controlling office with:
− A letter or application signed by the operator.
− The number of copies of the MEL as required by the controlling office.
2. The current requirements of CAR 37 and CAO 20.18 Para 10.
3. The necessity to provide a copy of the current version of the applicable
MMEL accepted/approved by the NAA of the country of certification if CASA does not
have a copy of the MMEL. For information on how to establish the applicability of the
MMEL for the aircraft see Figure 5.
4. The CAA, CARs or CAOs do not stipulate any specific format and/or contents of an
MEL. However, the format provided in CAAP 37-1 would aid the assessment of the
MEL, and it is also an internationally accepted format.
5. An MEL may cover more than one aircraft of the same type. However, all differences
in the items of equipment installed, if any, should be clearly mentioned by registration
mark in the applicability statement in the front of the MEL and specified against each
affected item in the MEL.
6. Availability of this manual. If appropriate, provide to the enquirer a copy of the
Flowchart—Operator Development of MEL (see Figure 6), which will guide the
operator on the sequence of activities to develop, review and approve an MEL.
7. An estimated date for the approval of the MEL. The time period varies depending upon
the complexity of the aircraft, assessment of MEL items outside the MMEL and quality
of the submission.
8. Where requested, an estimate of the fee for assessment of an application for the
approval or amendment to an MEL. This estimate should be based on the likely work

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hours involved in assessing the MEL, at the hourly rate published in the Civil Aviation
(Fees) Regulations 1995, as amended from time to time.
9. An application for amendment(s) of an approved MEL, together with appropriate
substantiation, should be forwarded to the controlling Region Office.
10. The current equipment list of the aircraft.
2.4 Procedures
2.4.1 Administrative procedures
The procedures listed in this section provide CASA staff with the guidelines required to assess
and grant approval of an MEL.
These procedures ensure that the tasks of assessing, coordinating and finally approving an
MEL are carried out in a standardised manner that will provide an auditable record of tasks
and actions carried out.
On receipt of a written application from an operator the following persons shall:
Administration Officer
1. Record the request into RM8.
2. Attach all correspondence to the relevant file in accordance with local office
procedures.
3. Assign an appropriate job/RM8 number to enable the tracking of attributable time and
calculation of costs.
4. Pass the file to the Certificate Team Manager.
The responsibility of cost keeping, invoicing and receipt of payments rests with the
Administration Officer.
MEL Review Group Coordinator
If requested, prepare an estimate of the cost of assessing the MEL and ask the applicant to
confirm acceptance of the estimated cost. If accepted, the applicant must pay the estimated
fee prior to any assessment being carried out, unless prior arrangements are in place for
payment. See the Sample Letter - Estimate of Costs for Assessing an Application for Approval
of an MEL at Figure 1.
No further action on the application must be taken until the applicant has paid the estimated
fee or prior arrangements are in place for payment.
Suitable procedures should be established with the MEL Review Group to ensure that staff
record cost-recoverable tasks.

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Figure 1: Sample Letter - Estimate of costs for assessing an application for approval of an MEL

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2.4.2 Assessing an MEL


MEL Review Group Responsibilities
1. Compare the MEL with the applicable MMEL, and the Australian Regulatory
requirements (eg, CARs, CAOs and Aeronautical Information Publication (AIP)) on an
item-by-item basis. CAR 50E creates an order of priority between inconsistent
documents. ADs (as instruments) take precedence over MEL/PU (as approvals).
2. Ensure that operations and maintenance (O and M) procedures are appropriate and
correctly recorded.
3. Ensure that the MEL does not deviate from the requirements given in:
a. TAC and Type Certificate Data Sheet (TCDS)
b. Aircraft specifications limitations section
c. AFM
d. ADs
e. Extended Range Twin Engine Operations (ETOPS)
f. Reduced Vertical Separation Minima
g. Required Navigation Performance
h. Supplemental Type Certificates or Australian Supplemental Type Certificates
i. CAR 35 modifications
j. Any other continuous airworthiness document.
4. Ensure that acceptable procedures are in place for the use and guidance of flight crew
and maintenance personnel.
Comparing the MEL with the MMEL and Australian Regulatory Requirements
The MEL must be compared with the latest issue of the applicable MMEL on an item-by-item
basis. If an operator chooses to add items that are not found in the MMEL (due to its particular
type of operation, regulatory requirements etc), a review must be completed in accordance
with Chapter 3 of this manual. The review ensures that these items do not affect the design
standards or safe operation of the aircraft and are not in conflict with the AFM or aircraft
specifications, modifications and any regulatory requirements.
In general, an MEL should not be less restrictive than the applicable MMEL for the type of
aircraft. If certain item(s) of the applicant’s MEL are less restrictive than the applicable MMEL,
the applicant must be advised that extensive qualitative and/or quantitative analysis may be
required. In certain circumstances, depending on the nature of further analysis required,
assessment of a less restrictive or additional item may cost much more than the total cost of
the MEL approval.
In general, non-safety-related equipment such as galley equipment, passenger convenience
items or optional items need not be listed in the MEL. If the applicant’s MEL contains
passenger convenience or optional items such as galley equipment, audio/video equipment,
overhead reading lamps etc that are not addressed in the MMEL, then the assessment of the
MEL should be carried out as follows:
• where passenger convenience items serve a second function, for example, movie
equipment being used for cabin safety briefings, operators must develop and include
operational contingency procedures in case of an equipment malfunction

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• where passenger convenience items are part of another aircraft system, (for example,
the electrical system), or interact with other system(s), procedures must be developed
and included in the MEL for deactivating and/or securing in case of malfunction.
Note: This does not imply that the aircraft may be operated with the item removed unless the
approved MEL explicitly allows the removal.

An MEL may be applicable to more than one aircraft of the same type. However, all
differences in the equipment/systems installed, if any, should be clearly mentioned by aircraft
registration mark.
Ensuring that operations and maintenance procedures are appropriate
The objective of O and M procedures is to provide all people using the document with clear,
concise directions on how they are to proceed in case of PU. The ‘O’ and M procedures form
part of the approved MEL.
Aircraft with an MEL item invoked that requires a maintenance procedure will be configured as
per the MEL and dispatched for the intended flight in accordance with the requirements of the
maintenance control manual (for class A aircraft) or other appropriately documented
procedures (for class B aircraft).
The operator is responsible for establishing and publishing the respective O and M
procedures mandated by the MMEL, in a form relevant to their operation.
Some manufacturers produce operations and maintenance procedures for use by operators
(Dispatch Deviation Guides, etc). These procedures, if appropriate for the operators, may be
submitted as part of the MEL.
It is acceptable to publish these procedures in a separate document and they will be
considered part of the MEL. However, clear referencing of the document must be made in the
maintenance system and the appropriate operating documents.
AWIs, Airworthiness Engineer, and FOIs should ensure that operators provide adequate
substantiating documents to support their MEL submissions.
These documents will provide additional information in relation to the operator’s MEL program.
(That is, amendments to the operator’s maintenance control manual and/or operations manual
will be required in order to detail individual responsibilities relative to MEL procedures.)
Operations Procedures
The MEL Review Group must ensure that where the (O) symbol appears in the MMEL, an
operations procedure has been developed for inclusion in the MEL that provides clear
direction to the flight crew. The only exception is when the procedure is contained in another
document that is always available on the flight deck, such as an AFM, aircraft operating
manual, or the company operations manual etc. In these cases, the MEL must refer to a
section of the appropriate document(s).
If considered necessary, a statement will be required from the applicant signed by chief pilot
(or type endorsed pilot for private aircraft) that O procedures in the MEL are appropriate to
achieve the applicable result in the Remarks or Exceptions column of the MEL and
justification for the development of these procedures must be provided. (See Sample
Statement of O and M Procedures at Figure 2).

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Maintenance Procedures
The MMEL may identify items that require a maintenance (M) procedure. If this is the case,
the MEL Review Group must ensure that relevant M procedure(s) have been developed for
the MEL that provide clear direction to maintenance personnel.
If considered necessary, a statement will be required from the applicant signed by an
appropriately qualified LAME that M procedures in the MEL are appropriate to achieve the
applicable result in the Remarks or Exceptions column of the MEL and justification for the
development of these procedures must be provided (see Sample Statement of O and M
Procedures at Figure 2).
Note: Guidelines for O and M procedures contained in MMELs are not adequate procedures.
Operators must develop detailed instructions for use by pilots and maintenance personnel that
are appropriate to the operator’s systems and type of operation.

Figure 2: Sample Statement of O and M Procedures

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Warning Signs and Placarding


While the MMEL for some items may require specific wording, in the majority of cases, unless
otherwise mentioned in the applicable MMEL, the placard wording may be left to the
operator’s discretion.
The operator must provide the capability and instructions to the flight crew to ensure that the
placard is in place prior to commencing the intended flight.
Ensuring that Procedures are in Place for the Use and Guidance of Flight Crews
The MEL Review Group must confirm that:
• the operator has established procedures for the use and guidance of flight crews, in
relation to the MEL
• the MEL procedures agree with those in the operator’s Maintenance Control Manual
(MCM) and other operating documents.
Note: Operators of class B private aircraft seeking to develop and use an MEL must have some form
of instructions and/or procedures in the MEL stating how the MEL is to be used.

Procedures for Invoking MEL Items


If there are no procedures for the invoking of MEL items within the operator’s organisation, the
AWI must, in addition to vetting the MEL, ensure these procedures are in place.
Where procedures for the invoking of MEL items are not contained within the MEL, but are
contained in the operator’s MCM, operations manual or an alternative document, these
documents must be available to the operating crew at all times.
These procedures must include, but are not limited to procedures for:
• placarding requirements as per the MEL
• dispatching of the aircraft with invoked MEL item(s) complete with conditions and
procedures
• controlling categorised repair intervals.
Placarding Procedures
The item of equipment with the PU must be placarded to inform anyone involved in the
operation of the aircraft of the inoperative condition(s) of the item. While the MMEL for some
items may require specific wording, in the majority of cases the placard wording is to be
determined by the operator. To the extent practicable, placards must be located as indicated
in the MEL, or adjacent to the control or indicator/equipment affected.
A placarding procedure must be established and set out in the MEL defining the method of
control of placards and must include:
• where practical ensure that all inoperative items are placarded
• placards are removed and accounted for when the defect is cleared.
Placards should be self-adhesive wherever possible. The placards may vary in size and
shape.
Note: The type of placard utilised must be durable and conspicuous in its nature and take into
consideration surface adhesion characteristics and the various operating environments.

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The placard may be in two parts:


• part one would list a description of the defect and defect control number and should be
attached to the Maintenance Release technical log for reference by the crew. An MEL
control sheet attached to the aircraft technical log or appropriate company document
could serve the same purpose.
• part two should list the system affected and the defect control number and be fixed in
the appropriate location.
When invoking an MEL item, the person responsible must:
1. identify, in the Maintenance Release, the aircraft technical log or appropriate company
document, the action that has occurred
2. identify the item with its MEL number
3. ensure that the placard is placed in an appropriate location.
If more than one placard is required for an MEL item, provision must be made to ensure that
all placards are removed when the defect is cleared.
If a defect occurs at a base station and the MEL does not require action other than placarding,
the flight crew may install a placard as required by the MEL.
Dispatch Procedures
The MEL is approved on the basis that all equipment will be operative for take-off unless the
appropriate MEL conditions are complied with.
Note: Use of the MEL is not applicable to discrepancies or malfunction that occur or are discovered
during flight. Once an aircraft moves under its own power, the flight crew must handle any
equipment failure in accordance with the AFM. A flight is considered to have departed when the
aircraft moves under its own power for the purpose of flight. Discrepancies occasionally occur
between the time the flight departs and the time it takes off. If the AFM contains procedures for
handling that discrepancy, or if the Pilot-in-Command (PIC) considers that the discrepancy does
not affect the safety of flight, the flight may continue. The discrepancy must be addressed prior
to the next departure.

Training (CAR 214—Commercial Operations)


Operators must develop an MEL training program for maintenance personnel that must be
approved prior to an operator commencing operations with an MEL.
Training Program—Maintenance Personnel
The training for maintenance personnel should include the MEL and MCM procedures dealing
with:
• use of, and compliance with, the MEL
• placarding of inoperative equipment
• maintenance release of an aircraft
• dispatching an aircraft
• any other MEL-related procedures, such as ETOPS etc.
To ensure company personnel remain current with these procedures, recurrent training is to
be conducted by the operator when required, or a controlled method put in place to alert staff
to any changes in MEL procedures.

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Training Program—Flight Crew


Operators must also provide flight crew personnel with MEL training, which should be included
as part of the CAR 217 check and training responsibilities.

The details of such a training program must be stated in the operator’s Operations Manual.
The flight crew training should include, but should not be limited to, the following:
• the purpose and use of an MEL
• operator’s procedures referred to under the heading Placarding Procedures on page
30
• procedures referred to under the heading Ensuring that Procedures Are in Place for
the Use and Guidance of Flight Crews on page 2-12
• the PIC’s responsibility with respect to all MEL procedures.
To ensure company personnel remain current with these procedures, recurrent training is to
be conducted by the operator when required, or a controlled method put in place to alert staff
to any changes in MEL procedures.
2.4.3 Repair Intervals
Each item of an MEL must be repaired within the specified repair interval. These intervals
limit the maximum time an aircraft may fly with inoperative item(s) of equipment and are
designated A, B, C or D.
Note: Repair intervals for class B aircraft being operated as private aircraft are not necessary, as long
as the aircraft serviceability meets the regulatory operational and airworthiness requirements.

Repair intervals for equipment fitted above the minimum regulatory requirements that are
specified “nil required for dispatch” may be selected by operators at their discretion.
Category A Items
Items in this category are repaired within the time interval specified in the remarks column of
the MEL, adjacent to the item. Whenever the specified interval is stated in cycles or flight time,
the time interval begins with the next flight.
Category B Items
Items in this category are repaired within three consecutive calendar days (72 hours),
excluding the day that the malfunction was recorded in the aircraft M/R or other approved
document.
Note: If an operator is unable to comply with a repair interval, or a one-time interval extension, CASA
may extend the repair interval for a Category B item for a maximum period of up to six days (i.e.
the initial three day extension plus an additional three days), where CASA is satisfied that the
extension would not have adverse effect on the safety of air navigation.

Category C Items
Items in this category are repaired within ten consecutive calendar days (240 hours) excluding
the day that the malfunction was recorded in the aircraft M/R or other approved document. For
example, if the fault was recorded at 10 am on 26 January the ten-day interval would begin at
midnight on 26 January and end at midnight on 5 February.

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Category D Items
Items in Category D are those items that can be left unrepaired for an extended time. Optional
equipment and other equipment which is permitted to be installed on or removed from an
aircraft in accordance with approved procedures belong to this category, provided that:
• unavailability of the item does not adversely affect crew workload
• pilots do not rely on the function of that item on a routine or continuous basis
• pilots’ training, subsequent habit patterns and procedures do not rely on regular use of
the item.
Items in this category shall be repaired within 120 consecutive calendar days (2880 hours),
excluding the day that the malfunction was recorded in the aircraft M/R or other approved
document.
Management of Repair Intervals
The operator must establish procedures whereby the maintenance control personnel
periodically review the deferred items. This is done to ensure that any accumulated deferred
items neither conflict with each other nor present an unacceptable increase in crew workload.
Notwithstanding the categorisation of item repair intervals, it should be the aim of each
operator to ensure that inoperative items are repaired as quickly as possible.
Extensions of repair intervals are permitted for spares procurement problems. Some holders
of delegations under CAR 37 may have the ability to extend category B and C repair intervals
based on the non-procurement of spare parts. In these cases the delegate must have
documented justification that the spares were not available from the manufacturer for the
period of the extension. The extension is permitted to cover this justified period plus an
additional three days for installation.
Note: Where the delegate extends a repair interval for a category B or C item, they must provide the
controlling CASA Airline/Area Office with notification within 24 hours of exercising the extension
authority.

2.4.4 Issue of MEL Approval


Form 1026 Aircraft Minimum Equipment List Approval Form (see Sample Aircraft MEL
Approval Form at Figure 4) lists the pages to be approved and includes space for comments
from the inspectors involved. This assists the CASA delegate in deciding as to whether the
approval is to be granted.
If the application is for the initial issue of an MEL, or the complete re-issue of an existing
document, a copy of the LEP must be attached to the approval form. A note should be made
on the MEL approval form referencing the attached LEP (rather than listing all the pages
within the body of the approval form).
Airworthiness Inspector/Delegate
1. The concurrence of all relevant disciplines is required prior to approval of the MEL. To
ensure this, each member of the group is required to sign the Approval Form.
2. After completion of the review process by the MEL Review Group, the MEL is given to
the CAR 37 delegate, who stamps and signs the LEP.
3. The MEL Review Group Coordinator passes the MEL to the Administration Officer with
a letter indicating CASA approval. The standard format for an MEL approval letter is
shown under the heading Sample Letter—MEL Approval at Figure 3.

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A copy of the MEL may be retained on the local office file.


Administration Officer
1. Calculates the total cost of the task using the cost recovery documentation on the file.
2. Requests additional payment from the applicant or requests a refund from Finance
Branch, as appropriate.
Note: The effect of section 97 of the Civil Aviation Act 1988 (CAA) is that if a fee is prescribed for the
approval of any document, then the document shall not be issued until the fee is paid.

3. On receipt of extra payment or following a refund, forwards the approved MEL with a
standard covering letter to the applicant.

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Figure 3: Sample Letter - MEL Approval

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Figure 4: Sample Aircraft MEL Approval Form

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2.4.5 Assessing Amendments to MELs


For initial approval, amendments to MELs must be handled according to the procedure
outlined in this Chapter.

Figure 5: Flowchart - Determining the applicability of an MMEL

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STOP
Are all instructions clearly
Is there an MMEL
understood? If not, clear
No for the aircraft
problems before continuing
type?
Discontinue Yes
Yes
Develop MEL
(Note: To be done item by
item)
Do I have a copy of
No
the MMEL? Yes
Acquire a copy
Yes
Are (O) procedures
No clearly written in MEL
Do I have a current and/or Ops Manual?
No Write to include
copy of the AFM?
clear procedures Yes
Acquire AFM Yes

Are (M) procedures


Do I have a copy of No clearly written in MEL
No and/or Ops Manual?
CARs and CAOs?
Write to include
Acquire clear procedures
Yes Yes
CARs and CAOs
Are all items
Have I used the No as restrictive as the
No CASA MEL MMEL?
Cannot be less
Preamble?
Include preamble restrictive Yes
Yes than MMEL STOP
Go back and recheck last 3
items to ensure they are
No complete
Is a LEP included?
Yes
Establish LEP Yes

Are procedures
Is a Revision established for (O) and
No No
Control page (M) procedures in MCM
included? and Ops Manual?
Establish all
Include a Yes procedures
Revision Control page to use (O) and (M) Yes
procedures
Is a Table of
No Have I established a
Contents included? No
training program?
Establish training
Include Table of Yes program for aircrew Yes
Contents
and ground staff
Are notes and
No definitions
included?
Submit MEL to CASA
Include notes
Yes for Approval
and definitions

Is the MEL format


No based on the CASA
MEL format?
Establish format
as suggested Yes

Figure 6: Flowchart—Operator Development of MEL

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PRELIMINARY
(5)
Does the MEL
N contain a 'Notes and
Definitions' section?
Receipt of application
Advise applicant to include a
'Notes and Definitions'
section
Has the applicant paid
the fee? Does the MEL follow (6)
No accepted
Yes format?
Advise the applicant
to pay the fees Suggest acceptable
format to applicant Review each item against the
Is there an MEL MMEL, TCDS, CAO, CARs,
Review Group AFM, AIP
established for this
aircraft?
Advise applicant MEL No
is being processed Are (O) procedures (7)
N clear, concise and
complete?
Establish MEL Review
Group
Advise applicant procedures
must be clear, concise and
complete
Acquire copies of (8)
Are (M) procedures
latest revisions of: N
clear, concise and
- MMEL
If considered necessary a complete?
- AFM
- CAOs and CARs statement mey be required
from the applicant signed by Yes Advise applicant procedures
- TCDS
the chief pilot (or must be clear, concise and
- AIP
type-endorsed pilot for complete
private aircraft) that O
procedures in the MEL are
Begin processing
appropriate
MEL application Are placarding (9)
No procedures clear, If considered necessary a
concise and complete? statment mey be required
Processing the Application from the applicant signed by
Advise applicant procedures an appropriately qualified
must be clear, concise and LAME that M procedures in
Yes
(1) complete the MEL are appropriate.
No Does the MEL
contain a LEP?
Advise applicant to Does the applicant
(10)
include a LEP No have precise Ops & MCM
Yes
procedures for the use of
(2) the MEL?
Is a Revision Advise applicant to
No Control page establish procedures
included? Yes

Advise applicant to Yes If any answer to questions 1 to 10 is


include a Revision NO, return the MEL to the applicant
Control page for corrective action
(3)
No Is a Table of
Contents included?

Advise applicant to Does the applicant


Yes (11)
include a Table of Contents have a MEL training
No
program (Ops &
Does the MEL (4) Maint)?
Advise applicant to
No include the establish procedures Yes
preamble?
Advise applicant to
include a Preamble
Yes
Approve MEL

Figure 7: Flowchart—CASA Approval of MEL

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2.5 MEL administration


2.5.1 Operator responsibility
To ensure that the MEL incorporates any changes to the aircraft configuration, operation or to
the CARs, CAOs, AIPs and other documents, it is the operator’s responsibility to ensure that:
1. all MELs are updated on a regular basis
2. an MEL review is conducted and documented at least annually.
These procedures should be documented within the operator’s MCM, or other suitable
documents.
2.5.2 CASA Responsibility
Control of Applicable MMELs
The Airworthiness & Engineering Branch is responsible for the control of the applicable
MMELs.
The MEL Review Group Coordinator should ensure that the operator has applied the latest
version of the applicable MMEL to develop the MEL.
Operators must be advised to contact the aircraft Type Certificate (TC) holder, who normally
provides MMELs along with a revision service. However, CASA may have a library copy of the
latest applicable MMEL approved/accepted by the NAA of the country of type design.
If CASA does not have a copy of the country of origin MMEL, the operator must supply one at
the time the application is submitted.

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Figure 8: Sample Letter—Requirement to Revise an MEL

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2.5.3 Office Record Retention


With each approved MEL the following must be retained on the appropriate file:
• the letter of request from the applicant
• any correspondence and file notes
• the MEL Approval form
• a copy of the approved LEP
• the MEL approval letter.
The same procedure applies for each subsequent revision to the MEL.

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3 Permissible Unserviceability Approval Process


3.1 Introduction to the PU Approval Process
3.1.1 Reasons for a PU
Situations often arise where an operator needs to fly an aircraft, but cannot comply strictly with
the specified standards. The regulations may permit such flights, provided an acceptable level
of safety is maintained. The minimum standards are specified in the TC and design and
operational requirements in the CARs.
A PU is an approval for a defect in, or damage to, an individual aircraft, assessed on a case-
by-case basis as a one-off approval.
An acceptable level of safety means that deficiencies can be accepted in a particular situation
where literal compliance with the applicable Australian Certification Standards and equipment
requirements cannot be met. In order to achieve an acceptable level of safety, the defective or
damaged component/item must be compensated for by other factors.
These specific situations are covered by CAR 37 and CASR 21.197. This Part deals with CAR
37 only.
CASR 21.197 is explained below, but is not covered under ‘Permissible Unserviceability’ as
the circumstances are different, and in most cases permission is granted only for a single
flight.
3.1.2 PU versus Special Flight Permit
Permissible Unserviceability
Under CAR 37, a defect in, or damage to, an Australian aircraft can be approved as a PU
subject to any condition(s) embodied in the approval. The aircraft still complies with the
applicable type design standards and is considered airworthy.
Special Flight Permit
CASR 21.197 gives permission for an Australian aircraft to be flown for a particular purpose.
For further information on a permit to fly, refer to the latest issue of Advisory Circular AC
21.9(0)—Special Flight Permits.
Methods of Justification
The assessment of an acceptable level of safety for a PU often involves more than one of the
following methods of justification:
• the equipment may be considered optional
• the equipment may be considered redundant
• a qualitative analysis
• a quantitative safety analysis.
Optional Equipment
When aircraft are approved with optional equipment on board (that is, over and above the
aircraft type certification equipment), there is no necessity for such equipment to be operative
if it is in excess of that required for safe operation for a particular flight condition or flight route
and does not interact with other system(s) or equipment. Approval of a PU may be granted on
this basis.

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Passenger Convenience Items


If the PU request concerns passenger convenience item(s) such as galley equipment,
audio/video equipment, overhead reading lamps etc which are not addressed in the MMEL,
then the assessment of the PU should be carried out as follows:
• where passenger convenience items serve a second function, such as movie
equipment being used for cabin safety briefings, operational procedures must be
included in the PU conditions
• where passenger convenience items are part of another aircraft system, for example,
the electrical system, or interact with other system(s), procedures must be developed
for deactivating and securing any inoperative item.
Redundant Items
If the purpose or function of a component or system can be carried out by some other item(s)
of equipment, then its unserviceability may be accepted on a redundancy basis, provided that
the alternative equipment is confirmed to be operating normally. Redundancy cannot be
claimed as justification for approval of a PU if the two (or more) sources of the function or
information are required by the aircraft type certification standards. In this case, another
means of justification such as the safety analysis method must be used.
Qualitative Safety Analysis
These analytical processes assess system and aircraft safety in a subjective, non-numerical
manner, based on experienced engineering judgement.
If an item is to be acceptable for approval as a PU, a qualitative safety analysis must be used
to consider the impact that the proposed inoperative item has on all other aspects of the
aircraft’s operation. The qualitative analysis must consider:
• the impact on crew workload and operating environment
• the impact of invoking multiple PUs or MEL items
• the impact of any other open existing defects
• the complexity of maintenance and/or operational procedures.
The process may reflect experience with previous PUs or MEL approvals.
Quantitative Safety Analysis
These analytical processes apply mathematical methods to assess system and aircraft safety.
If the operation of aircraft with an inoperative item cannot be justified by the previous means
or criteria, then a safety analysis must be carried out. This involves a quantitative analysis of
the likely risk of the worst effects that could result from additional failures, events and/or
environmental conditions occurring during a flight with the particular inoperative item in
question. It must be shown that, bearing in mind the reduced exposure time when operating
under a PU, the probability of a particular hazard is not increased beyond the levels dictated
by the minimum standards specified for the design and operation of the aircraft type.

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Note: 1. A previous PU approval of the same inoperative item on another or even the same aircraft
type does not, in itself, imply that the required level of safety has been met. Factors that
must be considered are similarity of system operation and similarity of the aircraft’s
operational role.
2. The analytical methods referenced above require evaluation by an appropriately qualified
individual. Whilst the operator may supply their justification, this must be verified by an
appropriately qualified CASA person who has the required experience.

3.1.3 Limitations and Conditions


In order to accept an item on the basis of an acceptable level of safety, it must be determined
that compensating factors, such as directions, limitations and conditions, will ensure that the
acceptable level of safety is maintained.

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3.2 Initial Enquiries Regarding Approval of a PU


3.2.1 Handling Enquiries
Enquiries in relation to approval of PUs must be referred to a CASA Region Office.
3.2.2 Provision of Initial Information
When an operator makes enquiries about being granted approval for operation of an aircraft
with inoperative items of equipment/damage on a one-off basis, the applicable office requires
the operator to provide the following information:
• a reference to the applicable MMEL—to determine whether or not the specific defect
or damage is covered under the MMEL.
• if necessary, an assessment by an appropriately licensed aircraft maintenance
engineer or delegate of CAR 35—CASA is required to ascertain if the deactivation of
the item will have any detrimental effect on the aircraft or a system.
• if required, an estimate of the fee for the assessment of an application for the PU—
based on the likely working hours involved in assessing the PU at the hourly rate
published in the Civil Aviation (Fees) Regulations 1995, as amended from time to time.
• if the operator agrees to proceed with the application, request that they formally apply
for the approval of the PU. They are required to provide the following information in
writing using Form 1028 Permissible Unserviceability Application:
− aircraft type and model
− aircraft serial number
− aircraft registration mark
− aircraft total time in service
− M/R endorsed under CAR 47 or 50
− information regarding unserviceable item
− ATA Item No
− part, P/N, S/N, etc
− any other current unserviceabilities
− problem with U/S item
− reason for the application and justification
− substantiation that the level of safety will be maintained by means such as:
o adjustment of operating limitations
o transfer of the function to an operating component
o reference to other instruments or components providing the required function
or information
o change in operating procedures or change in maintenance procedures, or
both
o proposed conditions for operation with the unserviceability
o deactivation/removal/placarding

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− an anticipated date for rectification of the unserviceability.


3.3 PU approval procedure
3.3.1 Scope of this Procedure
The procedures listed in this chapter provide CASA staff with the guidelines required to
assess and approve one-off PUs for items included or not included in the MMEL.
These procedures ensure that the tasks of assessing, coordinating and finally approving a PU
are carried out in a standardised manner that provides a credible record of tasks and actions
carried out.
3.3.2 Staff Responsible
The task of approving a PU may require coordination between technical disciplines and Safety
Assurance Branch specialists, as required. The delegate of CAR 37 is responsible for
coordinating the task.
Refer to Form 1027 CASA Assessment/Traveller Sheet, for areas of control and coordination.
3.3.3 PU Approval Procedure
Refer to Form 1027 CASA Assessment/Traveller Sheet, for control and coordination.
Administration Officer
On receipt of a written request from an operator, accompanied by sufficient data to permit
proper assessment by all disciplines as required:
1. Record the request in RM8 if required.
2. Attach all correspondence to the relevant file in accordance with local office
procedures.
3. Assign an appropriate job number to enable the tracking of the attributable time and
calculation of costs. Sufficient details should be recorded to enable a breakdown of
costs to the applicant’s satisfaction.
4. Pass the file to the Certificate Team Manager of the region office.
For applications outside normal working hours, the administration process may be completed
after the approval or rejection of the application.
The responsibility of cost keeping, invoicing and receipt of payments rests with the
Administration Officer at the local office.
Suitable procedures should be established with the assigned delegate of CAR 37 to ensure
that staff performing cost-recoverable tasks make the appropriate entries in the CASA system.
Certificate Team Manager
Refer to Form 1027 CASA Assessment/Traveller Sheet, for control and coordination.
1. Allocate the file to an appropriate AWI.
2. Consult other Managers for coordination between the relevant technical disciplines
and Safety Assurance Branch specialists, as required.
Airworthiness Inspector
1. Prepare an estimate of the cost of assessing the PU and ask the applicant to confirm
acceptance of the estimated cost. If accepted, the applicant must pay the estimated

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fee or give written assurance for payment on invoicing, prior to any assessment being
carried out. No further action on the application must be taken unless the applicant has
paid the estimated fee or given written assurance for payment on invoicing.
2. The AWI must check the application to ensure that the operator has had the M/R
endorsed as required by CAR 50.
Note: It is recommended that a Certification Statement from an appropriately licensed Aircraft
Maintenance Engineer (AME) should be provided with the application for the PU. The
Certification Statement should state that a technical assessment has been carried out on the
item that is defective or damaged. This is to ensure that the deactivation of the item will not
have any effect on, or cause degradation or loss of performance of, the aircraft or aircraft
system. If this cannot be ascertained, the operator may have to request an assessment by an
authorised person for CAR 35 or contact the manufacturer to seek advice and justification for
the PU application.

3. Allocate a PU number from the local office PU Register. The use of Form 1027 CASA
Assessment/Traveller Sheet, is strongly recommended. This sheet records
assessment decisions and forms part of the record for the aircraft file.
4. The defect or damage is then assessed as a PU under CAR 37. The assessment is to
be made on the basis of engineering and operational considerations and information
provided on Form 1028 Permissible Unserviceability Application form. The procedure
outlined in Flowchart—Assessment of Permissible Unserviceability at Figure 10 should
be used in carrying out the assessment for a PU.
3.3.4 Criteria for Assessment for Certification and Operational Standards
Criteria to be Considered when Assessing the Application
The following criteria are to be considered by CASA when assessing the application:
• have the certification standards been compromised? Refer to the applicable TCDS and
MMEL. Also refer to CARs, CAOs etc.
• is the equipment required by the aircraft’s Equipment List or by its TC?
− have AFM requirements been met? Where the delegate considers that an item
deviates from a limitation or an emergency procedure contained in the AFM, the
matter may have to be referred to the appropriate specialist in the Safety
Assurance Branch.
If an item is to be considered for a PU and is likely to affect the take-off, landing or
climb performance of the aircraft as presented in the AFM, then it must have
appropriate engineering justification, with revised performance data. This must
provide an acceptable level of safety for flight.
− is this equipment required by the type of operation (eg, VFR/IFR)? Refer to CAOs,
CARs and AIP.
− is the equipment required by CARs, CAOs-ADs? If so, the Safety Assurance
Branch specialist(s) may have to be contacted for exemption/exclusion.
− if the equipment is considered optional, then consideration should be given to the
following, even if no approval is required:
− crew workload
− the effect of interaction with other systems.

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• the applicant is still to be notified in writing if no approval is required. Information as


required should be given at this time.
Check the aircraft file for the existence of any other PU, exemption or exclusion, and consider
their effect as part of the assessment.
If any of the items listed above do not meet requirements, or are required for intended flight,
proceed as detailed under the heading Achieving an Acceptable Level of Safety by Other
Means below.
Achieving an Acceptable Level of Safety by Other Means
To achieve an acceptable level of safety with an item of equipment that is inoperative, a
Safety Analysis should be carried out. This is to determine the effect of the alternative means
that are proposed to recover or avoid the need for the lost function. Consider the following:
• effect of increase in crew workload, decrease in crew efficiency, and environmental
impact on the crew
• effect or interaction on other systems
• failure of backup to the original PU item
• performance degradation of system or the aircraft beyond acceptable limits
• is the alternative means based on redundancy? If so, check if this redundancy is
required by the TC requirements.
Examples of justification on the basis of an acceptable level of safety are given below:
Example #1
Defect—Taxi light inoperative.
PU—‘The taxi light may be inoperative for daylight operations only, provided the landing light
is operative.’
By limiting operations to daylight only, for a short term, the situations requiring an operative
taxi light are avoided. Further, placing a condition that the landing light be operative ensures
that any signalling use of lighting by day is adequately covered. This provides an acceptable
level of safety.
Example #2
Defect—Windshield wiper inoperative.
PU—‘One windshield wiper may be inoperative provided the aircraft is not operated in known
or forecast precipitation during intended take-off or landing.’
In this example, a windshield wiper is required for each pilot by the Australian standards, and
therefore literal compliance is not possible with the windshield wiper inoperative. However, the
specific avoidance of precipitation provides an acceptable level of safety.
If the Level of Safety is Considered Acceptable.
In such cases, the defect/damage may be approved under CAR 37. Conditions/limitations as
necessary for the PU approval are to be drafted for a set period of time.
Conditions and Limitations
• consider any additional O and M requirements for specific maintenance or operations
procedures to be carried out with the listed item inoperative
• placard the unserviceable item

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• consider repair intervals when establishing the validity period of the PU


• adjustment to operating limitations may have to be imposed
• for example non-revenue, carriage of passengers, icing conditions etc.
3.3.5 Issue of PU Approval
Delegate
1. PU approval is only given by a delegate authorised under CAR 37 after ascertaining
that all requirements have been met. The approval is given in writing, listing all
conditions for continued operation of the aircraft with the PU.
Note: Refer to Figure 9: Sample Letter – Approval for a sample letter approving a PU.

2. After approval is granted and all office actions have been completed, the Application,
Form 1027 – CASA Assessment/Traveller sheet and approved PU, along with all other
documentation, are entered in the aircraft file, and any other file as required by local
procedures.
Administration Officer
1. Calculate the total cost of the task using the cost recovery documentation on the file.
Note: The effect of section 97 of the CAA is that if a fee is prescribed in relation to the issue of a
document, then the document need not be issued until the fee is paid.

2. On receipt of extra payment or following the request for a refund, forward the approved
PU, signed by the delegate.

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Figure 9: Sample Letter – Approval for a sample letter approving a PU

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PU application
received

Initiate assessment
- Traveller Sheet
(form 1027)

Ensure M/R is
endorsed iaw CAR
(1988) 50
requirements

D
The aircraft is
Do CAR (1988) YES
47 conditions YES UNAIRWORTHY and
apply? maintenance is
required

NO
Is the item required:
1. for type of operation
Is there (i.e. IFR/VFR), or
an approved 2. by CAO/AIP/AD?
NO MMEL,
for this aircraft?
C

YES
C
YES NO NO

YES Does the defect


Is the defect interact with any Approve PU and
covered under existing apply limits &
MMEL? modifications or conditions iaw
repairs? MMEL

NO

Is the
item required by Carryout
Carry ourSAFETY
SAFETY
the aircraft equip
list, TC or STC?
YES
(see
ANALYSIS
ANALYSIS
Section3.1.3)
3.1.2)
B
(see Section

NO

Is
operation with
unserviceability YES
contrary to
AFM?

NO

Figure 10: Flowchart - Assessment of Permissible Unserviceability

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Assessment of Permissible Unserviceability (continued)

Does the
Is the item required: defective item interact
1. for type of operation Inoperative item is with other systems or
NO
(i.e. IFR/VFR), or optional equipment increase crew workload
2. by CAR/CAO/AIP/AD or change crew
routine habit?
YES
YES

D NO

Advise applicant to
seek exemption or
exclusion against the B
CAO/CAR/AD

Note: The M/R must be endorsed setting


Impose conditions and out the details of the unserviceability and
limitations as required, PU approved by the conditions and limitations for
including (O) & (M) CAR 37 delegate continued operation with the inoperative
procedures, repair (see section 3.3.5) item or damage. The endorsement must
interval also state that the M/R has effect subject
to those conditions.

YES

Acceptable level
B of safety
determined?

NO

The aircraft is Notify the


UNAIRWORTHY and applicant and
maintenance is complete AO
required actions

AFM - Aircraft Flight Manual


AIP - Aeronautical Information Publication
CAO - Civil Aviation Order(s)
CAR - Civil Aviation Regulation(s)
CDL - Configuration Deviation List
AO - Area Office
iaw - in accordance with
MMEL - Master Minimum Equipment
List/Australian Supplement
M/R - Maintenance Release
PU - Permissible Unserviceability
IFR - Instrument Flight Rules
VFR - Visual Flight Rules
TC - Type Certificate
STC - Supplemental TC

Figure 11: Flowchart—Assessment of Permissible Unserviceability continued

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