Juan Anton
Continuing Airworthiness Manager
Rulemaking Directorate
EASA
EASA/Estonian CAA Rulemaking Workshop
30/31 January 2013
European Aviation Safety Agency
Organisations and personnel involved in the continuing airworthiness of aircraft and components, including maintenance, shall comply with the provisions of Part-M and where appropriate those specified in Part-145 and
Part-66.
As a consequence, Part-M applies also to Part-145 organisations, in particular the following paragraphs:
Subpart D: Maintenance standards (maintenance data, performance of maintenance, aircraft defects)
Subpart E: Components (installation, maintenance, life limited components, control of unserviceable components)
Slide 2
European Aviation Safety Agency
Organisations involved in the maintenance of large aircraft or of aircraft used in commercial air transport, and components intended for fitment thereto, shall be approved in accordance with the provisions of Annex II (Part-145).
Slide 3
European Aviation Safety Agency
Requirements for approval of an organisation for maintenance of aircraft and components
Including facilities outside Member State if
Identified in exposition
Control procedures in place
Authority satisfied that they are integral part of the organisation
Slide 4
European Aviation Safety Agency
A rating: maintenance of aircraft and components (according to aircraft maintenance data) while installed on the aircraft (or temporarily removed to facilitate access)
B rating: maintenance on engines/APU and components
(according to engine/APU maintenance data) while installed on the engine/APU (or temporarily removed to facilitate access)
C rating: maintenance on components other than engine/APU.
D1 rating: NDT. Only required when the Part-145 performs NDT for other organisations (issuance of Form 1). This is a rating not related to particular aircraft, engines or components.
NOTE: Refer to M.A.502 for more details.
Slide 5
European Aviation Safety Agency
Component certifying staff is only required for B and C rated organisations. When these organisations need to carry out NDT as part of component maintenance, the
NDT should be carried out by personnel qualified in accordance with 145.A.30 (f).
These NDT personnel do not need to be certifying staff.
The component maintenance, including the NDT, should be released by appropriate component certifying staff.
The need for NDT certifying staff qualified in accordance with 145.A.30 (f) and 145.A.35 is only required for D1 rated organisations.
Slide 6
European Aviation Safety Agency
Accountable manager
Nominated persons
Accepted by authority, (EASA Form 4)
Quality manager
Accepted by authority, (EASA Form 4)
Sufficient staff
Man hour planning (all functions, also auditing staff).
Reviewed and revised at least every 3 months.
At least 50% employed staff (not contracted) in every workshop, hangar, flight line and shift, to ensure adequate organisational stability.
Slide 7
European Aviation Safety Agency
A licence
B1/B3 licence
B2 licence
C licence
Minor scheduled line maintenance and simple defect rectification (AMC
145.A.30(g)), personally performed in Part-
145 organisation.
Maintenance on structure, powerplant, and mechanical and electrical systems, avionic line replaceable units (with simple tests).
Maintenance on avionic and electrical systems.
Base maintenance of entire aircraft in
Part-145 organisation.
Slide 8
European Aviation Safety Agency
Cat. C
Cat. B1
Cat. A
Simple tasks
Slide 9
Cat. B2
Certifying
Base Engineer
Support staff
Certifying
Technician
Certifying
Line Mechanic
European Aviation Safety Agency
Cat. C
Optional
Cat. B1/B3 Cat. B2
Certifying
Technician
Certifying
Technician
Certifying
Line Mechanic
Cat. A
Simple tasks
Slide 10
European Aviation Safety Agency
Exemptions for certifying staff
Facilities outside EU / Line stations outside EU
National qualification
Conditions in Appendix IV
Repetitive pre-flight AD’s. Certifying staff authorisation to flight crew (if allowed by the AD).
Aircraft operating away from support location. Certifying staff authorisation to commander or flight engineer.
Maximum validity 1 year.
Aircraft grounded away from base (unforeseen) with no certifying staff available. One-off authorisations.
Reported to NAA within 7 days.
Rechecked if affect flight safety.
Slide 11
European Aviation Safety Agency
Qualification, training and record requirements are the same for certifying staff and for B1 and B2 support staff.
All of them must hold a Part-66 licence with the appropriate ratings and have a minimum of 21 years.
B1 and B2 support staff do not need to be nominated as certifying staff. May be done if this personnel is used also for line maintenance.
Slide 12
European Aviation Safety Agency
Available and used (scope of work)
Controlled and calibrated (as applicable)
Part M.A.402(f) requires verification to ensure that no tools or equipment are left inside aircraft/component
Slide 13
European Aviation Safety Agency
Documentation needed for components:
New components: EASA Form 1 or FAA 8130-3 or TCCA24-
0078 (or TCCA Form One).
Maintained components: EASA Form 1 or FAA 8130-3 (dual release) or TCCA24-0078/Form One (dual release)
Standard parts and materials (raw / consumable) do not need a
Form 1 or equivalent. Certificate of Conformance is enough.
Installer must check eligibility of component:
Particular attention to modifications and configuration of aircraft, engines, etc.
Slide 14
European Aviation Safety Agency
PMAs can be accepted if:
The PMA part is not a “critical component". The statement “This
PMA part is not a critical component” should be written in Block
12 of the FAA Form 8130-3; , or
The PMA part conforms to design data obtained under a licensing agreement from the holder of the FAA design approval.
The statement “Produced under licensing agreement from the
FAA design approval holder” should be written in Block 12 of
FAA Form 8130-3; or
The PMA part has received an explicit approval by means of a design change or STC from the Agency or, when this approval was granted prior to 28 September 2003, from any of the
National Aviation Authorities of the Members States of the
European Union. The reference to this authorization should be written in Block 12 of the FAA Form 8130-3.
Slide 15
European Aviation Safety Agency
145.A.42(c) allows fabrication of a restricted range of parts by the
Part-145 organisation:
Fabricated by the organisation (not by someone else).
To be used in the course of undergoing work (not for sale)
Within the technical and procedural capabilities of the organisation.
In accordance with approved procedures.
Using approved data (by TC holder or authority) contained in overhaul or repair manuals, SBs, etc, or as approved by authority.
Not eligible for issuance of Form 1.
Limited range (bushes, sleeves, shims, control cables, flexible and rigid pipes, electrical cable looms, formed or machined sheel metal panels, secondary structural panels and skin panels…).
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European Aviation Safety Agency
Hold and use current, available, applicable data in accordance with scope / capability
Requirements, directives, CDCCL etc. issued by authority
Maintenance / repair instructions issued by TC holder, Part-
21 organisation or oversight authority.
Standards, recognised standard practices.
Instructions modified by organisation iaw procedures.
May be provided by operator / customer (must be up to date).
Part-21 Subpart J Design Organisation may approve minor modifications and minor repairs (major repairs through EASA)
Slide 17
European Aviation Safety Agency
CRS issued by appropriate Certifying Staff on behalf of organisation before flight when
All maintenance ordered has been carried out in accordance with MOE procedures, using correct data and no known hazardous non-compliances (see AMC 145.A.50(a) 1.2)
New defects / incomplete work orders
Communicate rectification to operator
Maintenance not completed
Operator informed and agrees
Inform authority if in doubt
Details entered on release certificate
Operator’s agreement endorsed on certificate
Issue CRS within aircraft limitations.
Slide 18
European Aviation Safety Agency
Independent audits
Planned to cover all aspects in 12 months.
Represent complete maintenance activities.
Include product sampling.
Small organisations (<10) may contract auditing.
To other Part-145 organisation/person
Audits twice per year
Feedback reporting to nominated persons and accountable manager (may not be contracted).
Regular meetings Accountable Mgr and staff.
Retain reports 2 years after clearance findings.
Slide 19
European Aviation Safety Agency
Maintain aircraft / components (within scope and in accordance with MOE)
At locations identified in Certificate and MOE.
At line stations (listed in MOE).
At any location due to unserviceability of the aircraft or to support occasional line maintenance (procedure).
By other organisation working under its quality system
(see AMC 145.A.75(b)3).
Issue Certificates of Release to Service
Slide 20
European Aviation Safety Agency
The organisation shall only maintain an aircraft or component for which it is approved when all necessary facilities, equipment, tooling, material, maintenance data and certifying staff are available.
Slide 21
European Aviation Safety Agency
Notify authority (before the change takes place)
Change of name of organisation or main location
Additional locations
Accountable Manager
Other managers (nominated persons)
Facilities, equipment, tools, material procedures, scope of work, certifying staff that could affect the approval.
Possible conditions set by authority
Slide 22
European Aviation Safety Agency
Particular case of new Line Stations:
Addition of a new Line Station is considered a change.
Must be notified to the authority in advance.
The list in the MOE must be amended.
The change must be approved by the authority (no indirect approval possible):
By formal letter, or
By approval of the inclusion in the MOE.
The authority may perform a physical audit.
The authority may replace the audit by a documental assessment of the evidence and investigation performed by the organisation following approved procedures in the MOE.
This should only be possible if the competent authority does not have relevant findings open on the Quality System of the organisation.
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European Aviation Safety Agency
Unlimited validity
Continued compliance, appropriate handling of findings.
Access to the authority.
Not surrendered or revoked (return to authority)
Slide 24