Transcript Diapositive 1 - EASA | European Aviation Safety Agency

Opinion 02/2008
Amendment to Part-M for
aircraft not used in
Commercial Air Transport
Juan Anton
Rulemaking Directorate
EASA
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 1
European Aviation Safety Agency
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 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 2
European Aviation Safety Agency
Current requirements
For aircraft involved in Commercial Air Transport, most of
the Part-M requirements have been mandatory since 28
September 2005.
For aircraft not involved in commercial air transport, PartM requirements are not applicable yet (for countries that
have opted-out), but its implementation can not be
postponed further than 28 September 2008.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 3
European Aviation Safety Agency
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
2008.
This opinion contains only proposed changes to the rules.
The associated AMC and guidance material was described
in CRD 2007-08, and will be issued by EASA as soon as
the opinion is approved by the Commission.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 4
European Aviation Safety Agency
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 2007.
Further changes resulting from tasks M.017 and M.005,
published as NPA 2007-08 in June 2007.
 This resulted in CRD 2007-08, published in March 2008.
Reactions to both CRDs were taken into account before issuing
the final opinion 02/2008.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 5
European Aviation Safety Agency
Envisaged calendar
Opinion 02/2008 was published on 16 May 2008.
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 2007-08 due to the reactions received
during the CRD consultation process and due to any possible
changes incorporated during the EASA Committee of 16 July.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 6
European Aviation Safety Agency
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 2007-08, transitional measures have been
proposed.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 7
European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 8
European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 9
European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 10
European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 11
European Aviation Safety Agency
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
2008
28 Sept
2009
Expiration
of current
ARC
Re-issuance
or extension
by:
• a national
CAMO or,
• the NAA
28 Sept
2010
28 Sept
2011
Re-issuance or
extension by the
NAA
PART M / ARC
fully
implemented
28 Sept
2008
3 July 2008
28 Sept
28 Sept
2009
2010
Cologne: Part-M workshop (Opinion 02/2008)
28 Sept
2011
Slide 12
European Aviation Safety Agency
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
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 13
European Aviation Safety Agency
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
NPA2008-07:
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)
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 14
European Aviation Safety Agency
Requirements adapted to the aircraft
size
LSA aircraft (Light Sport Aeroplane) as proposed by
NPA2008-07:
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
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 15
European Aviation Safety Agency
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
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 16
European Aviation Safety Agency
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;
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 17
European Aviation Safety Agency
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”.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 18
European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 19
European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 20
European Aviation Safety Agency
"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
procedure" (M.A.302(c)):
what
is
an
"indirect
approval
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 21
European Aviation Safety Agency
"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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 22
European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 23
European Aviation Safety Agency
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".
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 24
European Aviation Safety Agency
Reliability Programmes
Opinion 02/2008 clarifies in M.A.302(f) that a Reliability
Programme is not required for non-large aircraft.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 25
European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 26
European Aviation Safety Agency
Use of FAA ACs 43-13 for repairs and
modifications
FAA ACs 43-13 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 2003.
Task MDM.032 (NPA2008-07) is envisaging creating CS
(Certification Specifications) to include material similar to the ACs
43-13.
In the meantime, ACs 43-13 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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 27
European Aviation Safety Agency
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
NPA2008-07 (task MDM.032).
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 28
European Aviation Safety Agency
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 8130-3 or TCCA 24-0078 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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 29
European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 30
European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 31
European Aviation Safety Agency
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)
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 32
European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 33
European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 34
European Aviation Safety Agency
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”
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 35
European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 36
European Aviation Safety Agency
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”.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 37
European Aviation Safety Agency
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 Part145.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 38
European Aviation Safety Agency
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)
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 39
European Aviation Safety Agency
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)
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 40
European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 41
European Aviation Safety Agency
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”.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 42
European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 43
European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 44
European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 45
European Aviation Safety Agency
Airworthiness Review Staff qualification
requirements for CAMOs and Competent
Authorities
“Experience
M.A.707(a))
in
continuing
airworthiness”
means:
(AMC
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
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European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
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European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 48
European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
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European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
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European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
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European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
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European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 53
European Aviation Safety Agency
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).
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
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European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 55
European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 56
European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
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European Aviation Safety Agency
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...”
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
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European Aviation Safety Agency
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
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
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European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
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European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
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European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
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European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 63
European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
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European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
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European Aviation Safety Agency
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))
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 66
European Aviation Safety Agency
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).
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
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European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
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European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
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European Aviation Safety Agency
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))
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
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European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
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European Aviation Safety Agency
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.
3 July 2008
Cologne: Part-M workshop (Opinion 02/2008)
Slide 72