Explanatory material for CRD to NPA 2013-01(B) status June 2015
WORKING DOCUMENT FOR FOCUSED CONSULTATION GROUP MEETING 01
TABLE OF CONTENTS
A. Objective and scope of this task ..................................................................................................................................... 2
B. Summary of NPA comments (Part-M and Part-145) ...................................................................................................... 5
1.
Rule structure: ....................................................................................................................................................... 5
2.
Applicability of the new management system framework (SMS) ......................................................................... 5
3.
AMCs and alternatives means of compliance: ...................................................................................................... 5
4.
Management of changes / Indirect approval / changes not requiring prior approval ......................................... 5
5.
HF and Fatigue risk management (FRM) in Part-145............................................................................................. 6
6.
Occurrence reporting ............................................................................................................................................ 6
SECTION B ....................................................................................................................................................................... 6
7.
Management system for competent authorities: ................................................................................................. 6
8.
Flexible oversight planning cycles and extension beyond 24 months: .................................................................. 6
9.
SMS related oversight: .......................................................................................................................................... 7
C. Proposal for applicability and proportionality of SMS .................................................................................................... 7
D. List of items for group information & discussion ......................................................................................................... 10
1.
Definitions ........................................................................................................................................................... 10
2.
Structure (limit duplicate content) ...................................................................................................................... 10
3.
Consistency between Part-M and ARO/ORO ...................................................................................................... 10
4.
Alignment with Regulation 376/2014 ‘Occurrence Reporting’ ........................................................................... 10
5.
Proportionality..................................................................................................................................................... 10
6.
SMS Implementation Support ............................................................................................................................. 10
7.
AMCs, altMOC and related application/approval procedures ............................................................................ 11
8.
CAME ................................................................................................................................................................... 11
9.
SMS – Organisation and responsibilities............................................................................................................ 11
10.
SMS Conceptual – Compliance Monitoring..................................................................................................... 11
11.
SMS Conceptual – Management system integration ...................................................................................... 11
12.
SMS Conceptual – Emergency Response Planning (ERP) ................................................................................ 12
13.
SMS – Human Factors ..................................................................................................................................... 12
14.
Oversight – Oversight programme & methods ............................................................................................... 12
15.
Oversight – Root cause analysis ...................................................................................................................... 12
16.
Management of changes / Indirect approval / changes not requiring prior approval ................................... 12
Part-M specific issues ....................................................................................................................................................... 13
E. Editorial and consistency changes (as proposed in the NPA) ....................................................................................... 14
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Explanatory material for CRD to NPA 2013-01(B) status June 2015
A. Objective and scope of this task
This task is to issue a CRD and Opinion for the introduction of SMS for Part-M Subpart-G
organisations.
The main objectives of the proposed regulatory changes are to:

ensure effective compliance monitoring and safety risk management in all continuing
airworthiness management and airworthiness review activities

ensure a harmonised implementation of the new management system requirements for all
Subpart G organisations which are either
o
approved as part of their AOC in accordance with Regulation (EU) 965/2012; or
o
approved as an ATO in accordance with Regulation (EU) 1178/2011 as last amended
by 290/2012;

promote an integrated approach to management systems for those organisations and
related oversight;

provide proportionate management system requirements for all Subpart G organisations not
directly or indirectly linked to an AOC holder, with due regard to the Agency’s General
Aviation roadmap.

amend Section B ‘Procedures for Competent Authorities’ to harmonise with the authority
requirements already applicable in the fields of ATM/ANS, aerodromes, aircrew and air
operations.

introduce additional changes to Sections A and B regarding the possibility for AOC holders to
contract continuing airworthiness management (RMT.0209, old M.014) based on the
outcome of NPA 2010-09 consultation.
Changes to Part-M Subparts A, B, C, D or E may be required as a result of the above changes.
Further changes to Section B to realise the full potential of alignment with the authority
requirements in the fields of aircrew and air operations (considering RMT.0516/0517 ‘review of
ARO/ORO’), as well as changes to Part-M/F, Part-145 and Part-147 will be assessed in a second
phase and are not part of this task.
Phase II will be subject to new ToRs and new NPAs.
A CRD for NPA 2013-01(B) for the scope outlined above (not including Subpart-F) will be completed
(individual responses to comments) and published together with the Opinion to be issued.
A regulatory impact assessment is to be provided with the Opinion, this should include more
quantitative elements as compared to the RIA included with the NPA. Focused Consultation Group
input will be sought.
For the specific scope of this task the number of comments to be considered is as follows:
Item
#
1 Explanatory material to NPA 2013-01(B)
2 Part-M Subpart G Section A and remaining Part-M excl. Part-M/F
3 Part-M Subpart G Section B
nb
67
238
54
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Explanatory material for CRD to NPA 2013-01(B) status June 2015
TOTAL *
359
A number of comments to NPA 2013-01(C) Part-145 relate to elements that are common to Part-M
and Part-145, therefore the real number of comments to be analysed and considered for this Opinion
is higher than in the above table.
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Explanatory material for CRD to NPA 2013-01(B) status June 2015
Planning milestones

Kick-off meeting 25 June 2015:
o Review ToRs and work package

Focused Consultation Meeting 02 - September 2015
o Review discussion items - FCG DOC 01
o Review resulting text (Opinion) – FCG DOC 02
o Review CRD inputs (responses) – FCG DOC 03
o Focus on Section A and Implementing Rules

Focused Consultation Meeting 03 - October 2015
o Review list of discussion items and resulting text of the Opinion and CRD inputs
o Focus on Section B and all AMCs and GM
o Work on RMT M.014 elements (contracting of CAMO)
o Work on RIA

Draft CRD & Opinion for EASA processing : end of October 2015 latest

Publication : November 2015
NB: The need for an additional group meeting will be determined after the EASA Committee
meeting. This would mainly focus on finalising AMCs and GM.
Mailing list focussed consultation group:
juan.anton@easa.europa.eu; karl.specht@easa.europa.eu; francis.jouvard@easa.europa.eu;
julia.egerer@easa.europa.eu; Edmund.bohland@easa.europa.eu; chris.drew@bainessimmons.com;
neil.richardson@bainessimmons.com; prosper.preau@airbus.com; Barbara.Weindl@alt-heliservice.de;
axel.soltysiak@lht.dlh.de; jim.pegram@easyJet.com; franck.sainton@aviation-civile.gouv.fr;
bob.rieder@minienm.nl; brian.spurle@caa.co.uk; Johan.Brunnberg@transportstyrelsen.se;
georg.Klose@austrocontrol.at; 'Franz Meier' fm.svfb@icloud.com; Roberts Simon Simon.Roberts@caa.co.uk;
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Explanatory material for CRD to NPA 2013-01(B) status June 2015
B. Summary of NPA comments (Part-M and Part-145)
More than 1300 comments were made to NPA 2013-01 and 192 comment to NPA 2013-19
(average: 2.71 per page, not that much compared to some other NPAs).
1.
Rule structure:
-
-
general support for the ARX/ORX approach, a few comments ask for the horizontal rule
structure to be adopted now (confirmed through the comments made to NPA 2013-19)
several commenters insist on the need to fully align with/strictly adhere to the text from the
aircrew/air operations regulation (Subparts GEN to ARX/ORX) with no deviations
113 detailed comments received (Airbus) asking for a further streamlining of Part-M and Part145, including in many areas beyond those directly related to SMS
duplication of content in each of the Parts (M/G, M/F, 145, and later on 147) not supported
2.
Applicability of the new management system framework (SMS)
-
a series of comments requesting:
o not to extend beyond Annex 19 SMS applicability
 no SMS in Part-147 organisations (‘no occurrences in a Part-147’)
 no SMS in Part-M Subpart F organisations
o to mandate SMS only for organisations working with aircraft used in CAT or CMPA
(both for Part-M and Part-145)
a series of comments indicating the need for SMS implementation guidance & implementation
support for:
o small organisations
o organisations that are not directly involved in aircraft operations
o general aviation organisations
comments from Industry (including from US industry / Boeing, P&W, AIA etc…) requesting not
to change the existing management system:
-
-
-
-
o ‘in maintenance all hazards are fully addressed by existing regulations‘
some comments indicate that the link between safety management and compliance
monitoring needs clarification.
3.
AMCs and alternatives means of compliance:
-
comments from Industry claiming that with the new requirements on alternative means of
compliance processing de facto all AMCs are gaining the status of implementing rules
comments from Industry and NAAs claiming that too many AMCs & GM are overly prescriptive
in nature, not compatible with performance based approach (e.g. fixed audit cycle for the
internal audit as defined in AMCs).
4.
Management of changes / Indirect approval / changes not requiring prior
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Explanatory material for CRD to NPA 2013-01(B) status June 2015
approval
-
many comments (industry and NAAs), partially contradicting, asking to review and clarify the
provisions
o do not change ‘indirect approval’
o provide approval privileges to organisations
o better clarify responsibilities of the authority in regards to documentation provided
for changes not requiring prior approval
o create better linkage with the change management process under the management
system (safety risk management)
5.
HF and Fatigue risk management (FRM) in Part-145
-
many comments on the reference made to the EU Working Time Directive & Fatigue Risk
Management Scheme in Part-145
o need for fatigue risk management challenged in some comments, others would like
to extend its scope
o reference to the Directive not supported (workaround has been prepared together
with EHFAG).
6.
Occurrence reporting
-
comments requesting to clarify how the provisions will be aligned with the European
Regulation (376/2014)
comments requesting NAAs to make their database available to Industry
comments stating that internal safety reporting systems should not be required in General
Aviation organisations
-
SECTION B
in general surprisingly low number of comments to Section B)
7.
Management system for competent authorities:
-
only 2 NAAs repeat some of the comments made when ARX/ORXs were drafted (‘no
management system requirements for competent authorities’)
8.
Flexible oversight planning cycles and extension beyond 24 months:
-
generally supported, but: the problem is that EASA cannot regulate charging schemes, ‘so the
effective use of extended oversight planning cycles will be close to zero’
several comments indicating the proposal needs to go further in relying on the organisational
capability to manage risks (‘give more privileges to organisations to manage changes under
their approval’)
introduction of an ‘annual programme validation inspection’ is not supported (as it goes
beyond what is defined in ARX).
-
-
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Explanatory material for CRD to NPA 2013-01(B) status June 2015
-
a few NAAs do not support possible consideration of certification in accordance with industry
standards.
9.
SMS related oversight:
-
several comments indicating the need for a common assessment tool for SMS effectiveness.
What are the risk ?
How are we mitigating ?
Is it working ?
C. Proposal for applicability and proportionality of SMS
Some comments requested this shall not go beyond applicability of Annex 19, meaning
that CAMOs not linked to an AOC holder should not be included.
For consideration:
-
EASA promotes the Total System Approach: ‘All organisations exposed to or
possibly contributing to aviation safety risks should have a management system
to ensure effective compliance and address safety risks entailed by their activities
and interactions with other organisations’.
-
Regulation 376/2014 on occurrence reporting applies to all CAMOs - an effective
management system is essential to build up a reporting scheme and just culture.
-
Consider that the EASA Management System framework is different from the
Annex 19 SMS framework – it is much more ‘objective based’ and builds upon the
existing quality system.
-
Consider the overall approach to effective safety performance management: A
Management system is a prerequisite for defining the authority ‘level of
involvement’ based on risks and performance.
Extract from the Explanatory Note (NPA 2013-01(A):
-
An efficient and effective management system requires the organisation to analyse and
assess its system, processes, and their interrelations in order to identify strengths, nonconformities, weaknesses, and hazards in view of ensuring continued compliance and
achieving continual improvement. This is not only most adequate in the EASA regulatory
and institutional system that relies on organisation approvals, but also probably best
adapted for the implementation of the ICAO SMS framework. The management system
requirements combine safety management and compliance monitoring provisions into a
single set of requirements. The proposed management system framework while addressing
all elements of the ICAO SMS framework as per future ICAO Annex 19, promotes an
integrated approach to the management of an organisation by including the additional
safety management components into the existing organisation requirements, rather than
adding them as a separate framework. This aims at encouraging organisations to embed
safety management into all safety relevant activities, instead of (super)imposing another
system onto their existing management systems.
-
Through the adoption of a common management system framework for all approved
organisations in the area of airworthiness, air operations, and air crew, the implementation
of safety management processes will be facilitated for those organisations holding more
than one approval. This approach entails a wider applicability of the EASA management
system framework compared to that of the existing ICAO SMS SARPS in Annexes 1 and 6
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Explanatory material for CRD to NPA 2013-01(B) status June 2015
which basically mandate an SMS only for those activities that are directly related to the
operation of aircraft. By contrast, the Agency is of the opinion that all ‘components’ of the
Air Transportation System, contributing with different degrees to the overall level of
safety, need to be considered. From a systems safety perspective, this will not only
support ‘interoperability’ of those components, but also encourage the adoption and
promotion of common principles and semantics in the area of safety management.
The below table provides an initial proposal to include management system requirements
based on Part-ORX in Part-M for Subpart G organisations, for discussion.
Type of
Operations
Aircraft type
A. CMPA1
CAT - AOC & licenced air carrier
(Reg. 1008)
Other commercial operations
cf. Reg. 216/2008 Essential
Requirements for air operations
§ 8(g)
Non-commercial &
Private following NCC
(CMPA) or NCO rules (nonCMPA)
Currently:
CAMO as part of AOC
Independent CAMO
consistency with ORX.GEN. Sec. II
(e.g. commercial ATO)
Independent CAMO
consistency with ORX.GEN.
Sec. II (NCC operators need to
declare their activity and
implement Sec.II
management system)
In the future:
Contracted CAMO
Note 1
B. Non-CMPA
> ELA 2
C. Up to ELA 23
Scalability: different AMCs for complex and for non-complex organisations
(as for Regulation 965/2012 and related AMCs/GM)
Currently:
Independent CAMO
CAMO as part of AOC
consistency with ORX.GEN. Sec. II
(e.g. commercial ATO)
No CAMO required
In the future:
Contracted CAMO
Case of ATOs to be assessed
– task MDM.047 introduced
consistency with ORX.GEN. Sec. II
the concept of ‘commercial
Note 1
ATO’ 2
Neither
965/2012,
nor
Scalability: different AMCs for
Scalability: different AMCs for
1178/2011 define what is to
complex and for non-complex
complex and for non-complex
be considered a nonorganisations
organisations
Optional: Organisations qualifying commercial ATO.
as non-complex may adopt
‘Organisational review’ (defined at
AMC level)
Currently: CAMO as part of AOC –
consistency with ORX.GEN. Sec. II
Note 1
In the future – Light Part-M (GA
Task Force: Independent CAMO
Independent CAMO
consistency with ORX.GEN. Sec. II
(e.g. commercial ATO)
Define these as non-complex organisations by default for the purpose of
Management System AMCs and GM and propose ‘Organisational review’
as a standard AMC
No CAMO required
Case of ATOs as above – one
option would be to exempt
all ELA 2 from the CAMO
obligation regardless of type
of operations, except for
licenced
air
carriers
(approved as part of the AOC)
CAT
CM
CMPA
Commercial Air Transport
compliance monitoring (internal auditing)
complex motor-powered aircraft
1
The term ‘other-than-complex motor-powered aircraft’ includes also non-motor-powered aircraft such
as sailplanes and balloons.
2
The term ‘commercial ATO’ used in the point M.A.201 (as per pending amdt. MDM.047) refers to a
training organisation approved pursuant to Regulation (EU) No 1178/2011 which, for commercial
purposes, operates aircraft for providing Part-FCL training courses. This explanation was given at the
EASA CMT in May 2014.
3
Those certified for max 4 occupants up to 1200 Kg MTOM, regardless of type of operation, meaning
applicability of the future Part-M ‘Light’.
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NCC
NCO
SRM
SA
OPS rules for non-commercial OPS with CMPA /Part-NCC = Annex VI to Reg. 965/2012
OPS rules for non-commercial OPS with other than CMPA/ Part-NCC = Annex VII to Reg. 965/2012
safety risk management
safety assurance (in terms of checking the effectiveness of SRM)
NOTE 1: full consistency with ORX.GEN. Sec. II
The table is based on the following assumptions:
(1)
Article 1.3 of Commission Regulation (EC) No 1321/2014 will remain unchanged. Therefore, all
provisions related to CAT are solely applicable to licensed air carriers as defined by
Community law (Regulation 1008), excluding in particular operators of balloons and sailplanes.
CAT operations by other than licenced air carriers are part of ‘Other commercial operations’.
(2)
No difference should be made between CAMOs having the Subpart I privilege and those not
having it.
(3)
Fair aircraft other than CMPA the determination of operations to be considered ‘commercial
operations’ would be made on the basis of the Cover Regulation to (EU) 965/2012, meaning
activities that are not subject to Part-NCO.
The case of ATOs needs to be discussed as Regulation to (EU) 965/2012 does not allow
determining when they operate commercially or not.
(4)
The principle to define two sets of AMCs to the new M.A.712 ‘Management system’ to reflect
the ‘complexity’ of the organisation, as underlying the rules in the area of aircrew and air
operations, would be transposed, with organisational complexity criteria defined in a
dedicated AMC to M.A.712 (as in the NPA).
The complexity criteria defined in AMC to M.A.712 as proposed with the NPA need to be
refined.
(5)
The alleviation introduced with amending Regulation (EC) No 1056/2008, ref. M.A.712(f)) to
allow organisations with no more than 5 full-time equivalents (FTEs) actively involved in
continuing airworthiness management tasks to replace the quality system (in the future:
compliance monitoring function) by an organisational review under certain conditions (not
issuing ARCs for a/c > 2730 kg MTOM) is maintained and it is proposed to extend this
possibility to cover all aircraft other than CMPA not used in CAT.
The type of organisational review will need to be further explored, one possibility could be
to include specific elements of the safety assurance function (monitoring effectiveness of
safety risk management) into the scope of the organisational review.
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D. List of items for group information & discussion
(based on NPA comment analysis cf. FCG DOC 02) changes will be in the revised draft
1.
Definitions
-
2.
Proposal (CAA UK) to create a GM to 1321/2014 centralising all definitions other
than those included at IR level already in one place
o Do not include definitions already included with 376/2014
Structure (limit duplicate content)
3.
Extract all Management System related GM and include them only once ?
Which GM could be left to safety promotion material ?
Consistency between Part-M and ARO/ORO
-
-
4.
Several comments insist on the need to fully align with/strictly adhere to the text
from the aircrew/air operations regulation (Subparts GEN to ARX/ORX) with no
deviations
Need to coordinate with RMT.0516 (first review of ARO/ORO) – also, a number of
changes proposed with NPA 2013-01(B) will be taken up for the ARO/ORO NPA.
RMT.0516 will deliver an Opinion in 2016 – full alignment will be difficult due to
differential schedules
Do we need to add IR elements on control of contractors to create an equivalent
to ORO.GEN.205?
Many detailed proposals (Airbus) to review in particular AMC material and further
align between Part-M and Part-145, including in many areas not directly related
to SMS
Alignment with Regulation 376/2014 ‘Occurrence Reporting’
-
5.
Coordination with new RMT.0681 (initiation still to be confirmed)
comments requesting NAAs to make their database available to Industry (SM.1
input)
comments stating that internal safety reporting systems should not be required in
General Aviation organisations (Reg. 376/2014 applies to all CAMOs)
Proportionality
Need to review AMC to M.A.712(b) with criteria for establishing organisational
complexity
-
Additional complexity elements – shift work - subcontracting
Proposed that some CAMOs are defined as ‘non-complex by default’ (those only
managing ELA2 non-CAT)
6.
SMS Implementation Support
Existing SMS guidance, including the ICAO SMM, is too ‘Operator’ centric
-
Consider creating SMS guidance specific to the area of Design, Manufacture ,
Maintenance & Maintenance management
To what extent can ESSI be used in this respect? Need for a new focus group
under ECAST/EHEST/EGAST?
Where to draw a line between elements to be included with the Decision (GM)
and material that can be developed under safety promotion?
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o
7.
ESSI: specific guidance on how to perform SRM, risk register examples,
GM on safety performance measurement, interface management,
integration etc…
AMCs, altMOC and related application/approval procedures
Flexibility:
-
comments from Industry claiming that with the new requirements on alternative
means of compliance de facto all AMCs are gaining the status of implementing
rules
-
comments from Industry and NAAs claiming that too many AMCs & GM are too
prescriptive in nature, not compatible with performance based approach (e.g.
fixed audit cycle for the internal audit as defined in AMCs)
Proportionality:
-
8.
altMOC approval procedures are seen as too burdensome – could an altMOC be
approved during an authority audit?
GA: would like to be able to reuse already approved altMOC without having to
reapply for approval
Persons applying for an altMOC
o How to ensure oversight over such altMOC?
CAME
-
9.
Some stakeholders would like to see a fully harmonised structure & layout of
organisation manuals across domains (airworthiness, aircrew, air operations).
Could Appendix V to AMC1 M.A.704 Joe BLOGGS PLC ‘Continuing airworthiness
management exposition’ be left out all-together ?
o to be reviewed as part as implementation support / Safety Promotion
material
SMS
-
10.
– Organisation and responsibilities
Safety Manager (SM): not part of the nominated persons – no need to require a
Form 4 for the Safety Manager
Need to define more specific training and qualification requirements for the safety
manager?
Integration with the Management System of the AOC holder in terms of safety
review board and safety action group?
Relationship (& hierarchy) Compliance Monitoring Manager (CMM) and SM to be
clarified
SMS Conceptual – Compliance Monitoring
11.
GM added to clarify that CM also needs to cover the CM function itself – this view
is challenged by some stakeholders
Need for GM on root-cause analysis of internal findings ?
Need for GM on typical methods for effective root cause analysis ?
SMS Conceptual – Management system integration
-
Clarify integration versus combination of MS
Ensure common understanding on MS integration and integrated approach to
managing safety
Provide GM on MS integration (see proposal made by DGAC-F) – consider SMICG
material being developed on integration
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12.
SMS Conceptual – Emergency Response Planning (ERP)
-
13.
What would be a CAMO emergency? Examples to be provided
Do we need to maintain this provision (AMC level) ?
SMS – Human Factors
-
14.
Some stakeholders challenge the inclusion of HF issues under SMS in general
terms.
Others see no need to strengthen HF in Part-M
One stakeholder considers that the NPA does not go far enough (FRMS also for
CAMOs) and suggests having common AMCs on FRMS for CAMOs and Part-145.
Consideration of HF principles for the design of the MP – now part of this RMT –
may need further GM
Oversight – Oversight programme & methods
-
-
-
15.
NAA comments opposed to the differences to ARA/ARO introduced with the NPA
(annual programme validation inspection)
Flexible oversight planning cycles and extension beyond 24 months:
o generally supported, but: ‘the problem is that EASA cannot regulate
charging schemes, so the effective use of extended oversight planning
cycles will be close to zero’
Credits in case of compliance with EN9110?
o EN9110 is relevant to maintenance, but not to continuing airworthiness
management
o Some NAAs do not support possible consideration of certification in
accordance with industry standards.
Proposed to add IR with ‘Findings and enforcement measures – persons’ based on
ARO.GEN.355 (independent CS and persons using altMOC)
Need for an agreed methodology to assess SMS effectiveness (RAG group will
deliver something in 2016) – reference to SMICG in the meantime?
Oversight – Root cause analysis
-
-
16.
Need for guidance on effective root cause analysis and how this should be
overseen by the competent authority (checking process versus checking
outcome)
Could be addressed as part of methodology to assess SMS effectiveness (RAG
group)
Management of changes / Indirect approval / changes not requiring prior
approval
-
Many comments (industry and NAAs), partially contradicting, asking to review
and clarify the provisions :
o
do not change terminology ‘indirect approval’
o
provide approval privileges to organisations
o
better clarify responsibilities of the authority in regards to documentation
provided for changes not requiring prior approval
o
create better linkage with the organisation’s change management process
under the management system (safety risk management)
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Part-M specific issues (initial list)
-
Task M.014 ‘Contracting of CAMO’ – relevant elements should be
incorporated as part of this Opinion
o contractual aspects
o CAMO – AOC holder interface etc…
o Oversight of the contractual arrangement
o Etc…
-
need for additional guidance on which type of CAM tasks can be outsourced by a
CAMO?
-
AMC1 to M.A.706(g) refers to 2730 kg – is this threshold still relevant?
-
Check references to maintenance post-holder in M.A.706 and M.A.712 for
consistency
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E. Editorial and consistency changes (as proposed in the NPA)
The term ‘approval’ has been replaced by ‘certificate’ when reference is made to the
organisation’s approval certificate as opposed to the process of approving it.
‘Quality System’ has been replaced by ‘compliance monitoring function ’throughout the
text.
‘Quality Manager’ has been replaced by ‘compliance monitoring manager’.
‘Surveyor’(competent authority) has been replaced by ‘inspector’ throughout Section B.
‘Sub-contract’ and its derivatives (subcontractor, subcontracted, etc.) have been
replaced by ‘subcontract’, ‘subcontractor’, etc. throughout the text.
References to Commission Regulation
Commission Regulation (EU) 1321/2014.
(EC)
2042/2003
have
been
updated
to
References to Commission Regulation (EC) No 1702/2003 have been updated to
Commission Regulation (EU) No 748/2012.
References to ‘Compliance with
o
o
o
applicable requirements
this Annex
this Part
have been reviewed for consistency. Where necessary these have been
replaced by a reference to ‘Regulation (EU) 216/2008 and its Implementing
Rules, Regulation (EU) 376/2014 and its Implementing Rules’
The numbering and format of those AMC and GM that have been amended in the course
of this rulemaking task has been aligned with the current EASA Rulemaking style guide,
which results in:
—
adding an AMC/GM number to those amended AMC/GM (e.g. : AMC1 M.A.712
instead of AMC M.A.712), including when there is only one AMC/GM;
—
adding a subtitle to all new AMC and GM; and
—
aligning numbered lists in the AMC/GM with the number format of the
Implementing Rile ((a),(b)(c) instead of 1., 2., 3.).
This results in the coexistence of two different standards for the numbering of AMC/GM
paragraphs and subparagraphs. For the final Agency Decisions to be issued following
adoption of the relevant amendments at Implementing Rule level, a consolidated version
of all AMC and GM to which uniform numbering styles will have been applied will be
published.
Additional items for group discussion
-
Reference to ‘organisation’ or to ‘Continuing Airworthiness Management
Organisation’?
-
Reference to ‘approval’ (process or specific approval item) versus ‘certificate’
(e.g. suspension of the certificate, validity of the certificate)
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