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3 July 2008 Cologne: Part-M workshop (Opinion 02/2008)Slide 1 Opinion 02/2008 Amendment to Part-M for aircraft not used in Commercial Air Transport Juan.

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Presentation on theme: "3 July 2008 Cologne: Part-M workshop (Opinion 02/2008)Slide 1 Opinion 02/2008 Amendment to Part-M for aircraft not used in Commercial Air Transport Juan."— Presentation transcript:

1 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008)Slide 1 Opinion 02/2008 Amendment to Part-M for aircraft not used in Commercial Air Transport Juan Anton Rulemaking Directorate EASA

2 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 2 Current requirements On 20 November 2003 the European Commission adopted Regulation (EC) 2042/2003, on the continuing airworthiness of aircraft and aeronautical products, parts and appliances, and on the approval of organisations and personnel involved in these tasks. This Regulation includes Implementing Rules (Part-M, 145, 66 and 147). In particular, Part-M introduces measures to be taken to ensure that airworthiness is maintained, included maintenance.

3 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 3 Current requirements For aircraft involved in Commercial Air Transport, most of the Part-M requirements have been mandatory since 28 September For aircraft not involved in commercial air transport, Part- M requirements are not applicable yet (for countries that have opted-out), but its implementation can not be postponed further than 28 September 2008.

4 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 4 Part-M Regulatory Impact Assessment and Consultation Process Article 7(6) of (EC) No 2042/2003 required the Agency to make an evaluation of the implications of the provisions of Part-M, and propose changes if it was found necessary. The final result is the opinion 02/2008 issued on 16 May This opinion contains only proposed changes to the rules. The associated AMC and guidance material was described in CRD , and will be issued by EASA as soon as the opinion is approved by the Commission.

5 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 5 Part-M Regulatory Impact Assessment and Consultation Process This opinion 02/2008 is the result of a long process that includes: NPA07/2005, published in June 2005, as a result of the Regulatory Impact Assessment performed by Air EuroSafe. This resulted in CRD 07/2005, published in April Further changes resulting from tasks M.017 and M.005, published as NPA in June This resulted in CRD , published in March Reactions to both CRDs were taken into account before issuing the final opinion 02/2008.

6 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 6 Envisaged calendar Opinion 02/2008 was published on 16 May This opinion will be debated at the EASA Committee to be held in Brussels on 16 July 2008 (including the Commission, EASA and representatives of all Member States). Approval by the Commission expected before 28 September 2008 following an accelerated commitology process, with a Decision issued by EASA immediately after containing the AMC material. This AMC and guidance material may differ slightly from the one published in the CRD due to the reactions received during the CRD consultation process and due to any possible changes incorporated during the EASA Committee of 16 July.

7 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 7 Transitional measures Due to the fact that the new requirements will not be approved until just before the end of the current deadline of 28 September 2008, and as it was already announced in NPA , transitional measures have been proposed.

8 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 8 For non-large aircraft not used in commercial air transport (until 28 September 2009) Article 3.4 (2042/2003): National continuing airworthiness management organisations may perform: Continuing airworthiness management tasks Airworthiness reviews Issuance and extension of airworthiness review certificates (ARC) Article 3.6 (2042/2003): The following documents are deemed as approved maintenance programmes: A maintenance programme approved or accepted by the competent authority, or A recommended schedule issued by the TC holder, or A maintenance programme issued by the competent authority. These documents shall be supplemented by the corresponding M.A.803 Pilot-owner maintenance.

9 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 9 For non-large aircraft not used in commercial air transport (until 28 September 2009) Article 4.4 (2042/2003): National maintenance organisations may perform maintenance and issue certificates of release to service for aircraft and components. Certificates of release to service issued by these national maintenance organisations on or before 28 September 2009 are deemed equivalent to those required by M.A.801 and M.A.802. AMC M.A.501(a) will also be amended for consistency. Article 5.1 (2042/2003): Certifying staff may be qualified in accordance with national rules.

10 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 10 For large aircraft used by a third country operator (until 28 September 2009) These are aircraft registered in an EU Member State, which are used by a third country operator, and for which the Member State of registry has not transferred the airworthiness responsibilities to the third country. The provisions applicable to commercial air transport do not apply to them, since they are not licensed air carriers as defined by Community Law (Article 1.3 of 2042/2003) Article 7.3(a) (2042/2003): No obligation to contract a CAMO: This is an opt-out that the Member State of registry may select to apply, in which case the continuing airworthiness can be managed in accordance with national rules. NOTE: Large aircraft not used in commercial air transport but used by an EU operator (or private person) are not eligible for this opt-out.

11 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 11 For aircraft not used in commercial air transport which are subject to M.A.201(i) (until 28 September 2009) These are aircraft for which the Member State requires to have a certificate for commercial operations other than commercial air transport. Article 7.3(a) (2042/2003): No obligation to contract a CAMO or an approved maintenance organisation: This is an opt-out that the Member State of registry may select to apply, in which case the continuing airworthiness can be managed in accordance with national rules and there is no need to make a contract with an approved maintenance organisation.

12 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 12 For all aircraft not used in commercial air transport (Issuance/extension of ARC following national rules) (new Article 3.5 of EC n°2042/2003 ) 28 Sept Sept Sept Sept 2011 Expiration of current ARC Re-issuance or extension by: a national CAMO or, the NAA Re-issuance or extension by the NAA PART M / ARC fully implemented 28 Sept Sept Sept Sept 2008

13 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 13 Requirements adapted to the aircraft size This opinion covers all aircraft not used in commercial air transport. However, in order to adapt the requirements to the associated risks, different requirements have been established for: Large aircraft Aircraft above 2730 Kg MTOM other than balloons Aircraft equal or below 2730 Kg MTOM and all balloons ELA1 aircraft CS-VLA, CS-22 and LSA aircraft

14 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 14 Requirements adapted to the aircraft size The following definitions apply: Large aircraft: aeroplanes above 5700 Kg MTOM and multi-engine helicopters. ELA1 aircraft (European Light Aircraft) as proposed by NPA : Aeroplanes, sailplanes and powered sailplanes below 1000 Kg MTOM (except complex motor-powered aircraft) Balloons up to: 3400m3 (hot-air), 1050 m3 (gas), 300m3 (tethered gas) Airships with a maximum of 2 occupants and up to: 2500m3 (hot-air), 1000m3 (gas)

15 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 15 Requirements adapted to the aircraft size LSA aircraft (Light Sport Aeroplane) as proposed by NPA : Not more than 600 Kg MTOM, and Maximum stall speed in landing configuration of 45 knots (CAS) at the maximum certificated TOM and most critical centre of gravity, and No more than 2 persons, including the pilot, and A single, non-turbine engine with propeller, and A non-pressurized cabin

16 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 16 Alignment with new Basic Regulation 216/2008 The new Basic Regulation introduces two new concepts: Complex motor-powered aircraft: an aeroplane: Above 5700 kg MTOM, or With more than 19 passangers, or A minimum crew of 2 pilots, or Equipped with (a) turbojet engine(s) or more than one turboprop engine, or a helicopter: Above 3175 Kg MTOM, or With more than 9 passengers, or A minimum crew of 2 pilots a tilt rotor aircraft

17 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 17 Alignment with new Basic Regulation 216/2008 Commercial operations: shall mean any operation of an aircraft, in return for remuneration or other valuable consideration, which is available to the public or, when not made available to the public, which is performed under a contract between an operator and a customer, where the latter has no control over the operator;

18 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 18 Alignment with new Basic Regulation 216/2008 In this opinion, reference to "complex motor-powered aircraft" has been made only in: 2042/2003, Article 2, item (k): definition of ELA1 aircraft. M.A.803(b): Pilot-owner maintenance. However, future rulemaking action may further extend this term since the new Basic Regulation does not refer to large aircraft.

19 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 19 Alignment with new Basic Regulation 216/2008 In this opinion, reference to "commercial operations" has been made only in: M.A.201(i): operators other than commercial air transport. M.A.305(b): use of operator´s technical log. M.A.606(h): certifying staff. Future rulemaking action will likely introduce wider requirements for aircraft used in commercial operations other than commercial air transport.

20 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 20 Who is the "competent authority New AMC M.1: A competent authority may be a ministry, a national aviation authority or any aviation body designated by the Member State and located within that Member State. A Member State may designate more than one competent authority to cover different areas of responsibility, as long as the designation decision contains a list of the competencies of each authority and there is only one competent authority responsible for each given area of responsibility.

21 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 21 "Indirect Approval Procedure" of maintenance programmes Current Rule M.A.302(e): The maintenance programme and its amendments may be approved through an "indirect approval procedure" established by the CAMO responsible for the management of the aircraft. Opinion 02/2008 clarifies what is an "indirect approval procedure" (M.A.302(c)): It is a procedure established by the CAMO, included in the exposition and approved by the competent authority (the one responsible for the oversight of the CAMO). In this case, there is no need for competent authority endorsement.

22 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 22 "Indirect Approval Procedure" of maintenance programmes Opinion 02/2008 addresses the case where the State of Registry is not the State responsible for the oversight of the CAMO. (M.1, paragraph 4(iii), and M.A.302(c)): Usually, the Member State of Registry is responsible for the approval of Maintenance Programmes. The "indirect approval procedure" is a procedure approved by the competent authority responsible for the CAMO. If the competent authority responsible for the CAMO is not the one from the Member State of Registry, the responsibility falls on the one from the State of Registry, unless there is an agreement. If there is no agreement, the "indirect approval procedure" can not be used on that particular aircraft.

23 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 23 Maintenance programmes not linked to an operator (independent CAMOs) Opinion 02/2008 introduces in M.A.709 the concept of BASELINE and GENERIC maintenance programmes: Purpose: permit the approval of the CAMO without having any customer. They are not real maintenance programmes because they are not applicable to any particular aircraft (need customization). Only for aircraft not involved in commercial air transport. Based on the maintenance programme recommended by the TC holder. "Baseline": for a particular aircraft type. "Generic": to cover several similar aircraft types.

24 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 24 Maintenance programmes not linked to an operator (independent CAMOs) AMC M.A.709 will be amended to show examples of "generic" maintenance programmes and to include: "Baseline" and/or "generic" maintenance programmes are not applicable to a particular "registration mark". Should be available to the competent authority prior to the CAMO approval and will be listed in the exposition (not in the Form 14). After the approval of the CAMO, these programmes shall be revised to include specific tasks for each contracted customer (for each registration mark), unless the customer already has an approved maintenance programme fot that aircraft. May be revised through the "indirect approval procedure".

25 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 25 Reliability Programmes Opinion 02/2008 clarifies in M.A.302(f) that a Reliability Programme is not required for non-large aircraft.

26 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 26 Operator´s Technical Log Opinion 02/2008 clarifies in M.A.305(b) that the Operator´s Technical Log is only required for commercial air transport and when required by the Member State for commercial operations other than commercial air transport.

27 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 27 Use of FAA ACs for repairs and modifications FAA ACs can not be considered an acceptable document in the EASA system since it can only be applied to minor repairs and, according to Part-21, classifying a repair as minor or major is a privilege of approved design organisations. This situation has nothing to do with whether Part-M or national rules apply, since the approval of repairs and modifications is regulated by Part-21, which is already applicable to aircraft not involved in commercial air transport since 28 September Task MDM.032 (NPA ) is envisaging creating CS (Certification Specifications) to include material similar to the ACs In the meantime, ACs can be used when the TC holder specify it in their maintenance data and, also, as a basis to propose repairs that will be subject to the approval of EASA or of an approved design organisation.

28 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 28 Installation of components Current M.A.501(a) requires that all components have an EASA Form 1 or equivalent prior to installation, unless otherwise specified in Part-145 and Subpart F. Opinion 02/2008 proposes an amendment in M.A.501(a) to deviate from this rule also in those cases where Part-21 allows it. The objective is to allow the fabrication of a certain range of parts by the owner without issuance of a Form 1, as currently envisaged for ELA1 aircraft in NPA (task MDM.032).

29 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 29 Installation of components (acceptance of USA and Canada maintenance release) EASA will amend AMC M.A.613(a), paragraph 2.8, to allow an approved maintenance organisation (Subpart F or Part-145) to issue a Form 1 for components maintained in the USA and Canada by maintenance organisations not approved in accordance with Subpart F or Part-145. The following conditions apply: Availability of an FAA or TCCA release, and Verification of compliance with all applicable ADs, and Verification that the component does not contain repairs or modification not approved in accordance with Part-21, and Inspection for satisfactory condition, and Issuance of a Form 1 in compliance with paragraphs 2.2, 2.3 and 2.4 of this AMC. The maintenance organisation issuing the Form 1 does not need to have the rating for the component. It is enough with the rating for the aircraft type in which the component is installed.

30 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 30 Component maintenance (M.A.502) The normal requirement is that component maintenance must be performed by approved organisations (C rated organisations). An EASA Form 1 must be issued. Nevertheless, component maintenance may be performed by independent certifying staff or A rated organisations when: Maintenance in the component is performed in accordance with aircraft maintenance data, and The component stays installed on the aircraft or it is temporarily removed. The competent authority may specifically agree that independent certifying staff or A rated organisations perform component maintenance in accordance with component maintenance data (AMC will clarify that this is limited to simple component maintenance). Under this paragraph, the component can not be released with an EASA Form 1, but in accordance with the aircraft release procedures.

31 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 31 Component maintenance (M.A.502) In addition, maintenance on a component while installed or temporarily removed from the aircraft and performed in accordance with component maintenance data may be performed by independent certifying staff in the following cases: For ELA1 aircraft (including CS-VLA, CS-22 and LSA): Component maintenance other than overhaul. Component complex maintenance tasks (Appendix VII) if the aircraft owner has agreed a programme of work with the competent authority. In addition, for CS-VLA, CS-22 and LSA: Overhaul of engines and propellers if the aircraft owner has agreed a programme of work with the competent authority.

32 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 32 Component maintenance (M.A.502) Component removal and installation from an aircraft is considered to be aircraft maintenance and not component maintenance. As a consequence, M.A.502 requirements do not apply in this case (AMC M.A.502)

33 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 33 Control of unserviceable components (M.A.504(b)) Current Rule M.A.504(b) and AMC material: Unserviceable components shall be identified and stored in a secure location under the control of the M.A.502 approved maintenance organisation until a decision is made on the future status of the component. M.A.801(b)(2) certifying staff performing aircraft maintenance should send, with the agreement of the aircraft owner/lessee, any unserviceable component to an approve maintenance organisation for controlled storage.

34 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 34 Control of unserviceable components (M.A.504(b)) Opinion 02/2008: M.A.504(b) has been amended to allow storage of unserviceable components in a secure location under the control of an approved maintenance organisation. For aircraft not used in commercial air transport, other than large aircraft, the person or organisation that declared the component unserviceable may transfer its custody, after identifying it as unserviceable, to the aircraft owner provided that such transfer is reflected in the aircraft/engine/component log book.

35 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 35 Facilities (for Subpart F organisations maintaining balloons and airships) AMC M.A.605(a) will read: For balloons and airships a hangar may not be required where maintenance of the envelope and bottom end equipment can more appropriately be performed outside, providing all necessary maintenance can be accomplished in accordance with M.A.402. For complex repairs or component maintenance requiring an EASA Form 1, suitable approved workshops should be provided. The facilities and environmental conditions required for inspection and maintenance should be defined in the Maintenance Organisation Manual

36 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 36 Certifying staff (for Subpart F organisations) Opinion 02/2008 introduces in M.A.606 provisions similar to the existing Part-145: For repetitive preflight ADs and for aircraft operating away from a supported location: The organisation may issue to the commander a limited certifying staff authorisation. Sufficient practical training must be provided.

37 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 37 Subcontracting of specialised services (for Subpart F organisations) Current Rule (M.A.615): Subpart F maintenance organisations do not have the privilege of subcontracting maintenance tasks. May be justified by the fact that they are not formally required to have a Quality System. Opinion 02/2008 introduces in M.A.615 the privilege of subcontracting but limited to specialised services (NDT, welding, heat treatment....). Conditions: The specialised service provider must be appropriately qualified. Under the control of the Subpart F organisation Procedures documented in the MOM. Coverage by the applicable Organisational Reviews.

38 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 38 Maintenance at any location (for Subpart F organisations) Current Rule (M.A.615): Allows the Subpart F organisation to maintain any aircraft/component for which it is approved at any location in order to rectify arising defects. Opinion 02/2008 further extends it to cover occasional maintenance, subject to the conditions specified in the exposition. This provision is similar to the existing Part- 145.

39 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 39 Approval of a CAMO (Form 14) The approval of a CAMO is issued on a Form 14 (see M.A.703), as shown in Appendix VI to Part-M Opinion 02/2008 introduces the following changes in Form 14: No reference to the maintenance programme in the Form 14. Now the reference must be included in the exposition. In the case of aircraft not involved in commercial air transport, the reference in the exposition should be to the "baseline" or "generic" maintenance programmes. The conditions specified in Form 14 have been adapted to allow management of aircraft used in commercial air transport (AOC) and management of other aircraft. AMC M.B.703 will provide acceptable ways of endorsing ratings in the Form 14 (type designations, series, aircraft categories, etc)

40 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 40 Privileges of the CAMO (extension of an ARC issued by NAA or another CAMO) New privilege M.A.711(a)4: Extend an ARC that has been issued by the NAA or by another CAMO. Conditions (described in M.A.901(f): Can only be done by the CAMO managing the aircraft. The aircraft must be in controlled environment with that CAMO. A copy must be retained (M.A.714(b)) Typical cases: An aircraft which is managed by a CAMO with no privileges to issue ARC´s. An aircraft which has been imported into the EU, for which the NAA has issued the initial ARC, and which is managed by a CAMO. An aircraft registered in the EU, operated by a third country operator and managed by a foreign CAMO (can not have privileges to issue ARCs)

41 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 41 Privileges of the CAMO (extension of an ARC issued by NAA or another CAMO) Personnel requirements associated to M.A.711(a)4: No need to have airworthiness review staff. It is only necessary to verify that the aircraft stayed in a controlled environment. The persons that are authorised to extend the ARC under this privilege must be listed in the exposition (see M.A.704(a)3 and M.A.706(c)). These persons must be formally accepted by the NAA (see M.A.706(c)). A new AMC M.A.706(c) will be introduced to state that airworthiness review staff are automatically recognised with authority to extend ARCs under M.A.711(a)4.

42 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 42 Privileges of the CAMO (removal of recommendations for certain aircraft) M.A.711(b)2: For balloons and any other aircraft of 2730 Kg MTOM and below, which are not used in commercial air transport, the recommendations have been removed except for the import of an aircraft. NOTE: For this type of aircraft, changes introduced in M.A.901 allow the CAMO to issue the ARC even if the aircraft has not been in a controlled environment. As a consequence, there is no point to have recommendations.

43 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 43 Airworthiness Review Staff qualification requirements for CAMOs and Competent Authorities Opinion 02/2008 introduces in M.A.707(a) alleviated requirements for organisations managing balloons and other aircraft of 2730 Kg MTOM and below not involved in commercial air transport: at least three years experience in continuing airworthiness, and; an appropriate Part 66 licence, or a nationally recognized maintenance personnel qualification appropriate to the aircraft category (when Part-66 refers to national rules) or an aeronautical degree or equivalent, and; appropriate aeronautical maintenance training, and; a position within the approved organisation with appropriate responsibilities NOTE: Similar provisions have been included in M.B.902(b) for the staff involved in Airworthiness Reviews within the Competent Authority.

44 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 44 Airworthiness Review Staff qualification requirements for CAMOs and Competent Authorities In addition, persons not meeting the requirement of an appropriate Part 66 licence may replace it by: For aircraft used in commercial air transport and aircraft above 2730 Kg except balloons: 5 additional years of experience in continuing airworthiness to those already required by M.A.707(a)1(a), which means a total of 10 years. For balloons and other aircraft of 2730 Kg and bellow, not used in commercial air transport: 4 additional years of experience in continuing airworthiness to those already required by M.A.707(a)2(a), which means a total of 7 years.

45 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 45 Airworthiness Review Staff qualification requirements for CAMOs and Competent Authorities AMC material will be introduced to clarify the following terms: experience in continuing airworthiness; to hold a position with the appropriate responsibilities, including: Independence from the airworthiness management process; Overall authority on the airworthiness management process. formal aeronautical maintenance training; appropriate aeronautical maintenance training; performance of an airworthiness review under supervision; continuing experience needed to keep the validity of an airworthiness review authorisation; minimum content of the airworthiness review staff records.

46 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 46 Airworthiness Review Staff qualification requirements for CAMOs and Competent Authorities Experience in continuing airworthiness means: (AMC M.A.707(a)) An appropriate combination of experience in tasks related to aircraft maintenance and/or maintenance management (engineering) and/or surveillance of such tasks. NOTE: Similar provision has been included in AMC M.B.902(b) for the staff involved in Airworthiness Reviews within the Competent Authority.

47 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 47 Airworthiness Review Staff qualification requirements for CAMOs Independence from the airworthiness management process may be achieved by: (AMC M.A.707(a)) Being authorised to perform airworthiness reviews only on aircraft for which the person has not participated in their management. For example, performing airworthiness reviews on a specific model line, while being involved in the management of a different model line. CAMOs with Part-145/Subpart-F approval may nominate personnel from their Part-145/Subpart-F organisation may be nominated as airworthiness review staff, as long as they are only involved in the maintenance of the aircraft but not involved in its maintenance management. Nominating as airworthiness review staff personnel from the Quality Department of the CAMO.

48 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 48 Airworthiness Review Staff qualification requirements for CAMOs Overall authority on the airworthiness management process of complete aircraft may be achieved by: (AMC M.A.707(a)) Nominating as airworthiness review staff the Accountable Manager or the Maintenance Postholder. Being authorised to perform airworthiness reviews only on those particular aircraft for which the person is responsible for the complete continuing airworthiness management process. In the case of one-man organisations, this person has always overall authority. This means that this person can be nominated as airworthiness review staff.

49 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 49 Airworthiness Review Staff qualification requirements for CAMOs For balloons and other aircraft of 2730 Kg MTOM and below, not used in commercial air transport: (AMC M.A.707(a)(2)) experience in continuing airworthiness can be full time or part-time, either as professional or on a voluntary basis. Appropriate aeronautical maintenance training may be demonstrated by documented evidence or by an assessment performed by the competent authority or by other airworthiness review staff already authorised within the organisation, in accordance with approved procedures. This assessment should be recorded.

50 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 50 Airworthiness Review Staff qualification requirements for CAMOs AMC M.A.707(b): An airworthiness review under supervision means under the supervision of the competent authority. If the organisation already has properly authorised airworthiness review staff, the competent authority may accept that the supervision be performed by this existing airworthiness review staff in accordance with an approved procedure. In such case, evidence of the airworthiness review performed under supervision should be provided to the competent authority together with the EASA Form 4.

51 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 51 Airworthiness Review Staff qualification requirements for CAMOs AMC M.A.707(c): In order to keep the validity of the airworthiness review staff authorisation, the airworthiness review staff should have either: been involved in continuing airworthiness management activities for at least six months in every two year period, or, conducted at least one airworthiness review in the last twelve month period. In order to restore the validity of the authorisation, the airworthiness review staff should conduct at a satisfactory level an airworthiness review under supervision.

52 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 52 Need for a Quality System (for a CAMO) M.A.712: The possibility has been added to have organisational reviews even for small organisations issuing ARCs for balloons and other aircraft of 2730 Kg and below not used in commercial air transport. In this case there is no need for an independent Quality System. This means that a one-man CAMO may issue ARCs for balloons and other aircraft of 2730 Kg and below not used in commercial air transport. M.A.712(f) has been aligned with M.A.712(e), making clear that organisational reviews are not possible when managing aircraft involved in commercial air transport. It has been stated in M.A.712(f) that contracting continuing airworthiness management tasks is not possible without a Quality System.

53 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 53 Need for a Quality System (for a CAMO) AMC M.A.712(f): The criteria to qualify as a small organisation (eligible for organisational reviews) has been changed from managing 5 large aircraft (10 small) to have up to 5 full-time persons in the CAMO (including all M.A.706 personnel). An equivalent proportional number of persons is acceptable when using part-time personnel. A new Appendix XIII to the AMC has been created to give guidelines on the content of the organisational reviews for CAMOs.

54 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 54 Certification authorisation issued by the owner in case of AOG CRD 07/2005 removed this provision from M.A.607(b) (where the Subpart-F was issuing the certifying staff authorisation in case of AOG) and transferred it, with some modifications, to M.A.801: In case of AOG, the owner may authorise any person, with not less than 3 years maintenance experience and holding the proper qualifications, to maintain according to the standards set out in subpart D and release the aircraft, provided there is no organisation appropriately approved under this Part or Part 145 at that location. This is valid for non-large aircraft not used in commercial air transport (those not required to go to a Part-145 organisation).

55 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 55 Certification authorisation issued by the Subpart-F organisation in case of AOG Opinion 02/2008, in addition to maintain the change proposed to M.A.801 by CRD 07/2005, has kept in M.A.607(b) the possibility for the Subpart-F organisation to issue a one-off authorisation in an AOG away from base situation.

56 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 56 Release of complex tasks for ELA1 aircraft Aircraft complex maintenance tasks (Appendix VII) for ELA1 aircraft can be performed by independent certifying staff if the aircraft owner has agreed a programme of work with the competent authority. The competent authority must be satisfied that the certifying person holds the appropriate: qualifications and recent experience maintenance data tools, equipment and materials and has access to appropriate facilities.

57 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 57 Pilot-owner authorisation (M.A.803) WHO IS THE PILOT-OWNER? Must hold a valid-pilot licence (or equivalent) issued or validated by a Member State for the aircraft type or class rating. AMC material will clarify that this includes the medical examination. Must own the aircraft, either as: Sole owner, or Joint owner. One of the natural persons on the registration form, or A member of a non-profit recreational legal entity (this legal entity must be specified in the registration document), directly involved in the decision making process of the entity and designated by the entity to carry out Pilot-owner maintenance. In case of joint ownership, the maintenance programme should contain the list of authorised pilots, or a procedure to handle such list separately.

58 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 58 Pilot-owner authorisation (M.A.803) WHICH AIRCRAFT ARE COVERED? Non complex motor-powered aircraft of 2730 Kg MTOM and below, sailplanes, powered-sailplanes and balloons, which are privately operated: Privately operated means not operated pursuant to M.A.201(h) and (i): M.A.201(h) covers commercial air transport. M.A.201(i) has been amended to read (instead of its operational activities): When an operator is requested by a Member State to hold a certificate for commercial operations, other than for commercial air transport...

59 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 59 Pilot-owner authorisation (M.A.803) WHICH TASKS CAN BE PERFORMED? Appendix VIII has been revised to contain the principles that must be complied to declare a task as Pilot-owner maintenance. An AMC has been created to show a representative scope of Pilot-owner maintenance tasks, with 4 tables for: Aeroplanes Rotorcraft Sailplanes and powered sailplanes Balloons and airships

60 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 60 Pilot-owner authorisation (M.A.803) PRINCIPLES FOR PILOT-OWNER TASKS (Appendix VIII) Competence and responsibility: The Pilot-owner is always responsible for the maintenance he performs. The Pilot-owner must satisfy himself, before the maintenance, that he is competent. The Pilot-owner (or his contracted CAMO) is responsible for identifying the Pilot-owner tasks in the maintenance programme and its update. The maintenance programme must be approved in accordance with M.A.302.

61 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 61 Pilot-owner authorisation (M.A.803) PRINCIPLES FOR PILOT-OWNER TASKS (Appendix VIII) The concept of Pilot-owner self assessment is based on the following compensating measures: Pilot-owner tasks do not include safety critical items. The tasks must be listed in the maintenance programme. If the aircraft is managed by a CAMO, this organisation can follow the effectiveness of the maintenance performed by the pilot-owner, and amend the maintenance programme accordingly. Even if the aircraft is not managed by a CAMO, there is still an annual airworthiness review by a CAMO or by the NAA.

62 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 62 Pilot-owner authorisation (M.A.803) PRINCIPLES FOR PILOT-OWNER TASKS (Appendix VIII) Tasks which cannot be carried out by the pilot-owner: Critically safety related tasks Tasks requiring removal of major components or major assembly Airworthiness Directives or Airworthiness Limitation Items Tasks requiring the use of special tools, calibrated tools (except torque wrenches and crimping tools) Tasks requiring test equipment or special testing Unscheduled special inspections (heavy landing check, etc) Tasks affecting systems essential for IFR operations Complex maintenance tasks (Appendix VII) and component maintenance per M.A.502.

63 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 63 Pilot-owner authorisation (M.A.803) PRINCIPLES FOR PILOT-OWNER TASKS (Appendix VIII) Tasks which can be carried out by the Pilot-owner: Simple visual inspections or operations to check for general condition and obvious damage and normal operation of the airframe, engines, systems and components. NOTE: Any task described in the Aircraft Flight Manual, as preparing the aircraft for flight (Example: assembling the sailplane wings or performing the pre-flight inspection), is considered to be a pilot task and is not considered a Pilot-owner maintenance task. Therefore, it does not require a Release to Service.

64 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 64 Pilot-owner authorisation (M.A.803) PRINCIPLES FOR PILOT-OWNER TASKS (Appendix VIII) Procedures when performing Pilot-owner maintenance: The maintenance data specified in M.A.401 must be available and must be complied with. A Release to Service is required, including details of the maintenance data used. The Pilot-owner must notify it to the contracted CAMO (if applicable) not later than 30 days after completion of the task.

65 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 65 Aircraft in controlled environment Aircraft in a controlled environment (M.A.901(b)): Continuously managed during the previous 12 months by a unique CAMO, and Maintained during the previous 12 months only by approved organisations. This includes: Pilot-owner maintenance performed and released by the Pilot-owner, as long as the CAMO managing the aircraft has been informed (M.A.901(b) and current AMC M.A.901(b)2). Pilot-owner maintenance performed and released by independent certifying staff (M.A.901(b)). This definition is valid for all aircraft and all types of operations.

66 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 66 Aircraft airworthiness review All aircraft used in commercial air transport, and Aircraft above 2730 Kg MTOM, except balloons If the aircraft is in a controlled environment, the CAMO managing the aircraft may (if approved) perform the airworthiness review and issue the ARC. It may also extend it twice. (M.A.901(c)) Even if the aircraft is in a controlled environment, a CAMO which does not manage the aircraft cannot issue the ARC. This CAMO may only (if approved) perform the airworthiness review and issue a recommendation. The NAA issues the ARC. (M.A.901(d)) If the aircraft is not in a controlled environment, no CAMO can issue the ARC. The CAMO may only (if approved) perform the airworthiness review and issue a recommendation. The NAA issues the ARC. (M.A.901(d))

67 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 67 Aircraft airworthiness review Aircraft of 2730 Kg MTOM and below and balloons, not used in commercial air transport Any CAMO may (if approved) perform the airworthiness review and issue the ARC. It does not matter whether the aircraft is in a controlled environment or not. (M.A.901(e)) If the aircraft is not in a controlled environment, nobody can extend the ARC. A full review is required. (M.A.901(e)) If the aircraft is in a controlled environment, the CAMO managing the aircraft may extend the ARC. (M.A.901(e) and M.A.901(f)) The owner of the aircraft may choose to have the airworthiness review performed and the ARC issued either by a CAMO (appropriately approved) or by the NAA. (M.A.901(h)2).

68 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 68 Aircraft airworthiness review (ELA1 aircraft) For ELA1 aircraft: Not used in commercial air transport, and Not affected by M.A.201(i) Independent certifying staff may perform the airworthiness review and issue a recommendation, with the ARC being issued by the NAA. Conditions: Certifying staff must comply with Part-66 and must have 3 years of experience in continuing airworthiness. Certifying staff must be formally accepted by the competent authority after: Verification of their qualifications. Satisfactory performance of an airworthiness review under the supervision of the competent authority. This option can only be applied 2 consecutive years. Once every 3 years, the review must be performed by a CAMO or by NAA.

69 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 69 Extension of an ARC Remember: The new M.A.711(a)4 and M.A.901(f) allow the CAMO managing the aircraft to extend an ARC that was issued by the NAA or by another CAMO, as long as the aircraft is in a controlled environment.

70 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 70 Aircraft airworthiness review by the competent authority The competent authority performs the airworthiness review themselves (and issue the ARC) in the following cases: When a potential safety threat exists. (M.A.901(h)1) When requested by the owner of an aircraft of 2730 Kg MTOM and below and balloons, not used in commercial air transport. (M.A.901(h)2) For aircraft not used in commercial air transport, when the aircraft is managed by a third country CAMO (can not have privileges to perform airworthiness reviews and issue ARCs). (M.A.901(i))

71 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 71 Part-M, Appendix III Airworthiness Review Certificate Form 15a has been amended to align with Form 15b. Now, both certificates show: is considered to be airworthy at the time of the review Forms 15a and 15b have been amended to: allow the extension of the ARC by a CAMO (see M.A.711(a)4) where the ARC was initially issued by the NAA or different CAMO. Change the reference from regulation 1592/2002 to regulation 216/2008.

72 European Aviation Safety Agency 3 July 2008 Cologne: Part-M workshop (Opinion 02/2008) Slide 72 Part-M, Appendix VII Complex Maintenance Tasks Appendix VII has been revised to incorporate complex maintenance tasks related to piston engines and propellers. The purpose of Appendix VII is to provide those tasks that need to be performed in an approved maintenance organisation because they are likely to involve the use of special tooling, equipment and facilities.


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