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If a large commercial part 121 aircraft has lost it's airworthiness, and remained in that state for several months while being operated despite the loss of the airworthiness, what inspections and documentation are needed to make this airliner airworthy again per FAA or EASA rules?

For clarity, let us assume the airworthiness is lost due to lack of required maintenance, and the period of operation after the loss of airworthiness is not fully reliably documented.

Edit: By coincidence, I am now able to provide you with a real life example of such a situation:

Bermuda revokes licences of over half of Russia's airline fleet

“International sanctions on the aviation sector have had a significant impact on the ability to sustain safety oversight on Russian operated aircraft on the Bermuda Aircraft Registry. The airworthiness system has been restricted to the point that the Bermuda Civil Aviation Authority is unable to confidently approve these aircraft as being airworthy.”

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    $\begingroup$ I'm not sure what you mean by "losing" an airworthiness certificate? They don't expire, so are you asking about a scenario where the FAA took action to revoke it? If it wasn't revoked then you'd just need to get the maintenance done. $\endgroup$
    – Pondlife
    Commented Mar 12, 2022 at 20:23
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    $\begingroup$ @Pondlife Standby, let me get my terminology checked... $\endgroup$
    – Jpe61
    Commented Mar 12, 2022 at 21:03
  • $\begingroup$ When you say “lack of required maintenance” are you thinking about an AD that hasn’t been complied with or just an annual or 50/100 hr (or whatever period part 121 requires) inspection? Or something else? $\endgroup$
    – Jim
    Commented Mar 13, 2022 at 18:28
  • $\begingroup$ @Jim please see the edit I just made. $\endgroup$
    – Jpe61
    Commented Mar 13, 2022 at 19:50

2 Answers 2

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Airworthiness is a matter of passing inspections to ensure the aircraft still complies with its original Airworthiness Certificate and any Airworthiness Directives that have been issued since then.

If you’re doing the necessary maintenance to keep a plane safe for flight, it’s a relatively minor thing to do the inspections too and keep it airworthy. In fact, you’re probably discovering much of the need for said maintenance as part of your inspection program in the first place.

If you can’t perform the maintenance needed to pass an inspection, whether that’s due to a lack of parts, labor or cash, then the plane should be grounded until you can.

It doesn’t matter whether the aircraft is grounded for a day or a decade; as soon as it can pass the appropriate inspections, it’s airworthy again as if nothing had happened.

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  • $\begingroup$ Thank you for your answer. The point here is, that the aircraft remains in use despite lack of proper maintenance, and the documentation of this continued operation may be questionable. I'd give an example, but my original question about this was deemed opinion based when I did so... $\endgroup$
    – Jpe61
    Commented Mar 13, 2022 at 7:15
  • $\begingroup$ @Jpe61 Flying an unairworthy aircraft doesn’t change what has to be done to make it airworthy again. $\endgroup$
    – StephenS
    Commented Mar 13, 2022 at 14:20
  • $\begingroup$ it does in the sense that operating the plane under obscure conditions makes it harder to determine what needs to be done to regain airworthiness. "all" is obviously not an answer, as that would be quite an ordeal 😏 $\endgroup$
    – Jpe61
    Commented Mar 13, 2022 at 19:53
  • $\begingroup$ @Jpe61 It’s still the same inspection. Flying in the meantime may add some extra wear and tear that needs more repairs, but not doing the required maintenance means your planes may stop flying anyway—and rather abruptly. $\endgroup$
    – StephenS
    Commented Mar 13, 2022 at 20:44
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Without being able to give any example, I would say the procedure is the same as with airplanes that have been kept in long term storage or have been in an accident.

As far as lack of maintenance is concerned, improperly or insufficiently maintained parts will need to be replaced, restored and/or maintained, depending on the extend to which damage (due to irregulatory treatment) can be determined. Just like after an accident. If part of its operation is undocumented this only raises the scrutiny. Anything that doesn't have a history, has to live up to the same standards as everything else that doesn't have a history. You know,... new stuff.

The aircraft doesn't 'lose' its airworthiness certificate, but it will remain grounded until above mentioned maintenance is completed to the extend that the aircraft can be and actually is deemed airworthy by someone who is authorized to do so.

In practice this means an aircraft is patched up until it is in a state that allows for a special ferry flight permit, so it can be flown to a location where it can be made ready for operation. I used to work for an airline that bought a 747 that slipped off the side of a Greek runway. That went just fine. It looked like a pile of junk when it first rolled in, but looks don't matter for airworthiness. We had a bill for high speed tape like you wouldn't believe anyway, so it didn't bother us much either.

As far as the FAA is concerned, airplanes don't die and only very seldom lose type airworthiness. When it does happen, this results mostly from a change in the rules, rather than a faulty or unjustified type certification. Rule change most often leads to a mere change in an airplanes certification, rather than it being all out revoked.

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