3.9Conformity to the MMEL

3.9.1 Modification of MMELs and TC Supplements

Air operators may disagree with the content of the MMEL or TC Supplement and request changes to their MEL. These suggestions for changes, accompanied by appropriate substantiation, should be forwarded through their MEL Coordinators and/or POI/PMI for assessment. The Aircraft Certification Flight Test Division will review submissions and may modify the MMEL or TC Supplement where appropriate. Alternatively, an air operator may contact the manufacturer directly with a request to review the MMEL. If the MMEL originates in the U.S., an air operator may submit requested changes to a Flight Operations Evaluation Board (FOEB). These FOEBs, comprised of representatives from industry, government and the manufacturer, meet periodically to update MMELs. The schedule is available from the Air Transport Association of America (ATA) telephone (202) 626-4000, or on the http://www.faa.gov/aircraft/draft_docs/fsb/ website.

3.9.2 MEL Content

  1. The air operator's MEL must reflect the current MMEL limitations unless otherwise authorized by a change in the MMEL, or the TC Supplement. When a revision is issued to a MMEL or TC Supplement, the air operator's MEL need not be revised if the change is less restrictive than the existing MEL. Where a conflict exists between Transport Canada and the air operator concerning MMEL relief for a certain item, the air operator's MEL may be approved without relief for the contentious item, until the dispute can be resolved. In this case, Aircraft Certification Flight Test shall be notified and a request for revision initiated in accordance with Section 2.5.4.

  2. Except as noted above, all items installed in an air operator's aircraft which are addressed in the most recent approved version of the MMEL or TC Supplement, shall be included in the MEL. At the same time, an air operator or pilot retains the option to refuse any alleviation, and may choose not to dispatch with any particular MEL item inoperative.

3.9.3 Administrative Control Items

Some air operators use their MEL as a comprehensive document to control items for tracking and informational purposes. In such cases, air operators' MELs may include items not contained in the MMEL; however, no relief may be granted for these administrative control items unless conditions and limitations are contained in an approved document other than the MMEL (e.g., aircraft flight manual). Administrative control items and passenger convenience items may not include items or subsystems of items which are addressed in the MMEL. Air operators seeking to add administrative control items to their MEL must submit their request to their PMI or POI with appropriate substantiation.

3.9.4Passenger Convenience Items

Passenger convenience items are those items related to the convenience, comfort, or entertainment of an air operator's passengers. They may include items such as galley equipment, movie equipment, ash trays, (except exterior lavatory door ashtrays), stereo equipment, and overhead reading lamps. Passenger convenience items do not carry a specific repair interval, and need not be listed in an air operator's MEL, if they are not addressed in the MMEL. The exceptions to this rule are:

  1. Where passenger convenience items serve a second function, such as movie equipment being used for cabin safety briefings, air operators must develop and include operational contingency procedures in case of an equipment malfunction; or,

  2. Where passenger convenience items are part of another aircraft system, for example, the electrical system, procedures must be developed and included in the MEL for deactivating and securing in case of malfunction.

3.9.5MEL Audits

  1. Whenever an audit is conducted, the air operator's MEL shall be reviewed. The review shall ensure that the MEL conforms to Transport Canada current policies and procedures.

  2. Special attention should be given to operating rules that may have been amended since the MEL was last approved. It shall be confirmed that the latest revisions to the MMEL, the TC Supplement and any TC Global Changes - if more restrictive, have been incorporated into the MEL.
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