Guide to an Effective Embodiment Policy for Non-Mandatory Information

Last week, we reflected on the tragic accident of Air India Flight 171, where 260 lives were lost in the first fatal crash involving a Boeing 787 Dreamliner. While the full causes are still under investigation, the non-adopted advisory highlighted in the preliminary report points to a broader challenge for operators: how to effectively manage non-mandatory information—such as modifications or inspections that may impact the airworthiness of the aircraft.

Non-mandatory information refers to Service Bulletins, Service Letters, and other communications issued by an approved design organisation, the manufacturer, or the competent authorities, such as Safety Information Bulletins (SIB) issued by EASA and Special Airworthiness Information Bulletins (SAIB) issued by the FAA (*). While their adoption is not legally required, unless later mandated through an Airworthiness Directive (AD), this information can carry significant safety and airworthiness implications and should be carefully evaluated within a structured embodiment policy.

(*) When an airworthiness concern has not yet been determined to be an unsafe condition and does not warrant an AD, but requires alerting, informing, and drawing the attention of the aviation community, it is typically issued through these specific bulletins.

According to ICAO Annex 6, “the air operator should obtain and assess continuing airworthiness information and recommendations and implement any necessary actions in accordance with a procedure acceptable to the State of Registry.” In alignment with this, regulatory frameworks like EASA require operators to assess such non-mandatory data and determine whether to incorporate the recommendations. This is not merely a matter of preference; it must follow a formal, documented process grounded in technical analysis, risk assessment, and cost-effectiveness evaluation.

The Embodiment Policy: Balancing Safety and Strategy

A well-structured Embodiment Policy ensures that decisions around non-mandatory recommendations are made systematically, rather than reactively or arbitrarily. The goal is to strike a balance between safety, reliability, operational efficiency, and economic sustainability.

An Embodiment Policy should not be to adopt all non-mandatory recommendations or not to adopt any. Incorporating all the recommendations is not cost-effective and may increase the probability of maintenance errors. Not incorporating any requirement may lead to lower levels of safety and reliability, and also increase the costs. Instead, the operator should define clear evaluation criteria and responsibilities across departments, using a structured safety risk management process.

Key Components of an Effective Embodiment Policy

These are our recommended steps operators should establish in a formal procedure to evaluate non-mandatory recommendations, including modifications and inspections, and decide on their application.

1. Evaluation

• Technical Analysis: This step examines the current configuration and condition of the affected component or system. This involves checking the Aircraft Maintenance Program (AMP) to understand existing maintenance requirements, identifying any prior modifications already applied, and analyzing in-service data collected through the Reliability Program. The goal is to understand how the aircraft or system is currently configured and how it has been performing in service before deciding on any new changes.

• Safety Risk Assessment: The operator assesses whether the safety concern raised in the recommendation is applicable to its fleet and evaluates the likelihood and severity of potential hazards. This step may be skipped for non-safety-related changes (e.g., optional cabin enhancements).

• Return on Investment (ROI) / Cost-Benefit Analysis (CBA): ROI focuses on the direct economic benefits compared to the costs involved, such as reducing maintenance downtime or improving flight dispatch reliability. The broader CBA looks beyond just dollars and cents, factoring in less tangible benefits like enhanced passenger experience or positive impacts on the airline’s brand and reputation.

2. Decision & Justification

Based on the findings, a documented decision is made. Options include full fleet embodiment, selective embodiment (e.g., one aircraft as a test case), or non-implementation. Considerations like remaining lease time, operational impact, and alignment with company standards influence this decision.

3. Recording

Every step, from evaluation through to final decision, must be recorded in the Continuing Airworthiness Management Organization’s system. Transparency and traceability are essential for audits, future reference, and reliability tracking.

4. Monitoring

If a recommendation is adopted, its effectiveness must be monitored through the operator’s Reliability Program. If it is not adopted, the operator should periodically review this decision in light of any new data or changing operational conditions. This ongoing analysis ensures that safety and reliability are maintained, and that future decisions remain well-informed.

Note: Non-mandatory recommendations can evolve quickly. Operators may initially adopt repetitive inspections outlined in a Service Bulletin (SB) into the Aircraft Maintenance Program (AMP) while waiting for a more permanent terminating action. Others may test solutions on a sample basis before full-scale implementation. It’s important to understand that the AMP reflects a snapshot in time, what’s included in the latest AMP revision may not capture every dynamic update in real-time. This is why such information is considered a dynamic source for the AMP.

A Team Approach: The Modification Embodiment Policy Board

In larger organizations or when dealing with major modifications, it may be beneficial to establish a cross-functional decision-making body. A Modification Embodiment Policy Board, comprising representatives from Technical Services, Maintenance Programs, Reliability, Materials, Finance, and other departments, ensures that all relevant technical, operational, and financial perspectives are considered in the final decision.

Conclusion

Operators must actively review and assess non-mandatory recommendations that could impact the airworthiness of their operations. A clear Embodiment Policy is not just a best practice, it’s a regulatory requirement cascaded won from ICAO.

By combining technical insight, safety principles, economic analysis, and effective governance, operators can navigate the complexities of non-mandatory recommendations with confidence. In doing so, they ensure that safety, reliability, and financial priorities all remain in balance.

For those seeking a deeper understanding of managing Aircraft Maintenance Programs and continuing airworthiness, including best practices for a comprehensive Embodiment Policy that balances safety, reliability, and financial considerations, our Aircraft Maintenance Programs course provides detailed insights and practical guidance.