6 Part-145 approved maintenance organisation
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Transcript of 6 Part-145 approved maintenance organisation
25 January 2012 SAMA Information Day (Olten, Switzerland)
Part-145: Approved Maintenance Organisations(Annex II to EC 2042/2003)
Juan AntonContinuing Airworthiness Manager
Rulemaking DirectorateEASA
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 2
EC 2042/2003 Article 3
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)
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 3
EC 2042/2003 Article 4
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).
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 4
145.A.10 Scope
Requirements for approval of an organisation for maintenance of aircraft and components
Including facilities outside Member State ifIdentified in expositionControl procedures in placeAuthority satisfied that they are integral part of the organisation
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 5
145.A.20 Terms of approval
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.
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 6
145.A.20 Terms of approval
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.
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 7
145.A.30 Personnel requirements
Accountable manager
Nominated persons Accepted by authority, (EASA Form 4)
Quality managerAccepted by authority, (EASA Form 4)
Sufficient staffMan 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.
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 8
145.A.30 Personnel requirements
Category Release to Service privileges
A licence
Minor scheduled line maintenance and simple defect rectification (AMC 145.A.30(g)), personally performed in Part-145 organisation.
B1/B3 licenceMaintenance on structure, powerplant, and mechanical and electrical systems, avionic line replaceable units (with simple tests).
B2 licence Maintenance on avionic and electrical systems.
C licenceBase maintenance of entire aircraft in Part-145 organisation.
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 9
145.A.30 Personnel requirements (large aircraft)
Cat. C
Cat. B1 Cat. B2
Cat. B1 Cat. B2
Cat. A
Line
Base
Mechanic Avionics
Simple tasks
CertifyingBase Engineer
CertifyingTechnician
CertifyingLine Mechanic
Support staff
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 10
145.A.30 Personnel requirements (other than large aircraft)
Cat. C
Cat. B1/B3 Cat. B2
Cat. B1/B3 Cat. B2
Cat. A
Line
Base
Mechanic Avionics
Simple tasks
CertifyingTechnician
CertifyingLine Mechanic
Certifying Technician
Optional
or
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 11
145.A.30 Personnel requirements
Exemptions for certifying staffFacilities 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.
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 12
145.A.35 Certifying staff and support staff
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.
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 13
145.A.40 Equipment, tools and materials
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
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 14
145.A.42 Acceptance of components
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.
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 15
145.A.42 Acceptance of components
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.
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 16
145.A.42 Acceptance of components
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…).
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 17
145.A.45 Maintenance Data
Hold and use current, available, applicable data in accordance with scope / capability
Requirements, directives, CDCCL etc. issued by authorityMaintenance / 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)
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 18
145.A.50 Certification of maintenance
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 completedOperator informed and agrees
Inform authority if in doubtDetails entered on release certificateOperator’s agreement endorsed on certificateIssue CRS within aircraft limitations.
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 19
145.A.65 Quality system
Independent auditsPlanned 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.
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 20
145.A.75 Privileges
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
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 21
145.A.80 Limitations on the organisation
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.
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 22
145.A.85 Changes to the organisation
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
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 23
145.A.85 Changes to the organisation
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.
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 24
145.A.90 Continued validity
Unlimited validity
Continued compliance, appropriate handling of findings.
Access to the authority.
Not surrendered or revoked (return to authority)
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 25
Future changes
On-going and future rulemaking tasks
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 26
Future changes
Task 145.022 “Control of contracted maintenance personnel”
Decision 2011/011/R published on 28 November 2011.
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 27
Future changes
Task 145.017 “Control of suppliers for components, parts and appliances”
Clarify the requirements and produce guidance on how to evaluate component suppliers.
Evaluate the possibility to use industry standards and accreditation programmes in order to reduce the auditing burden when a supplier is used by many maintenance organisations.
NPA expected second quarter 2012.
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 28
Future changes
Task MDM.075 “Specialized tasks”
Currently, the Part-145 approval ratings only cover the specialized task of NDT (D1 rating).
This task covers additional tasks such as welding, plating, etc.
Task planned to start in 2012.
25 January 2012 SAMA Information Day (Olten, Switzerland)
European Aviation Safety Agency
Slide 29
Future changes
Task 145.024 “Functions and responsibilities of B1 and B2 support staff”
The ToR has been already published.The objective is to clarify the following:
How the organisation evaluates the complexity of each task and assigns it to personnel authorised to “sign-off” or to non-authorised personnel under supervision.
Who can be authorised to “sign-off”, under which qualification and under which authorisation process.
What is the role of the “sign-off” personnel and the “B1 and B2 support staff”.
How are recorded the actions taken by “sign-off personnel” and “B1 and B2 support staff”.
This is a Group task.