Transcript Diapositive 1 - European Aviation Safety Agency

NPA 2007-09
WG145.012: Single and
multiple releases
Juan Anton
05 July 2007
Cologne
European Aviation Safety Agency
Current certification system
Current Part-145 requirements for certification of
aircraft maintenance:
145.A.50(a): “A certificate of release to service shall be
issued by appropriately authorised certifying staff when
it has been verified that …..”
145.A.50(b): “A certificate of release to service shall be
issued before flight at the completion of any
maintenance”.
05 July 2007
WG 145.012: Single and multiple releases
Slide 2
European Aviation Safety Agency
Current certification system
Currently, two different certification systems coexist in
Europe:
Single release:
Maintenance tasks are signed-off by authorised
personnel.
A final CRS is issued before flight by certifying
staff.
Multiple release:
Each organisation may issue one or several CRS,
each one of them covering one or several tasks.
05 July 2007
WG 145.012: Single and multiple releases
Slide 3
European Aviation Safety Agency
Current certification system
Single release system:
Advantages:
All actions are certified by a single person who is
also responsible for coordination.
The pilot knows that when the CRS is issued it
means that all maintenance has been completed
and the aircraft is ready for service.
05 July 2007
WG 145.012: Single and multiple releases
Slide 4
European Aviation Safety Agency
Current certification system
Single release system:
Shortcomings:
It is not clear how this system can address the
case where several organisations are involved:
 Which organisation is responsible for the final
CRS?
 The person issuing the final CRS must have
capability to sign for all the work.
 The person issuing the final CRS is responsible
for the work performed by all organisations.
Usually, in this case, the system becomes a
Multiple Release System where each organisation
issues a CRS for its own work.
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WG 145.012: Single and multiple releases
Slide 5
European Aviation Safety Agency
Current certification system
Multiple release system:
Advantages:
From a practical point of view, the system is more
flexible, allowing each individual to be responsible
for his own work.
It allows, in Line Maintenance, the use of several
category A certifying staff, without intervention of
B1 or B2 license holders.
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WG 145.012: Single and multiple releases
Slide 6
European Aviation Safety Agency
Current certification system
Multiple release system:
Shortcomings:
When several organisations or individuals are
involved in a maintenance event, there could be
lack of coordination (work performed in 2 engines
requiring in some cases a flight test, functional
tests that can not be performed until another
organisation finishes its work….)
It is more difficult to ensure compliance with all
the work ordered by the operator.
It is more difficult for the pilot to know when all
maintenance has been completed and when the
aircraft is ready for service.
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WG 145.012: Single and multiple releases
Slide 7
European Aviation Safety Agency
Current certification system
Issues related to the coexistence of both systems
In addition to lack of standardisation, there may be
safety issues:
Example:
An operator performing maintenance in different
countries may receive release documentation
issued under both systems. This may lead an
operator used to receive a final CRS to think that
the aircraft is ready for service when receiving a
CRS under a multiple release system, which may
not be true.
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WG 145.012: Single and multiple releases
Slide 8
European Aviation Safety Agency
Task 145.012
A working group was created, with members from
Industry, NAA´s and EASA.
12 meetings (2 full days each) were held between
July 2005 and April 2007
Very different points of view.
Rulemaking action would affect only Part-145
organisations. Subpart-F environment requires a
much lower level of coordination (more simple
maintenance requirements & fewer contracted
organisations)
Rulemaking action affects aircraft maintenance (not
component maintenance).
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WG 145.012: Single and multiple releases
Slide 9
European Aviation Safety Agency
Possible options
Option 1: Do nothing (coexistence of 2 systems)
Option 2: Single CRS with coordination (currently exists):
Base Maintenance: tasks are signed-off. Each
organisation issues a CRS and there is a final CRS.
Line Maintenance: tasks are signed-off and there is a
final CRS.
No formal concept of PMO (Primary Maintenance
Organisation) responsible for coordination and issuance
of final CRS.
The final CRS certifies that the aircraft is ready for
service but the other CRS don´t.
Option 3: Multiple CRS (currently exists)
One or several CRS issued by each organisation, both in
line and base maintenance. Each CRS covers one or
several tasks.
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WG 145.012: Single and multiple releases
Slide 10
European Aviation Safety Agency
Possible options
Options 4a & 4b: Multiple maintenance certification and
final CRS
One or several MRC (Maintenance Release Certificate)
issued by each organisation. Final CRS issued by PMO.
Different options in line maintenance depending on
whether the organisation issuing the final CRS is the
one that performed the maintenance or not. May not be
necessary the issuance of the MRC.
Option 5:
One MRC issued by each organisation both in line and
base maintenance. Final CRS issued by PMO.
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WG 145.012: Single and multiple releases
Slide 11
European Aviation Safety Agency
Possible options
A consensus could not be reached as to what option
should be selected, and an Option 6 was proposed
(combination of Options 2, 4a, 4b and 5). This Option
6 was agreed by the majority of the group.
Option 6 was based on the concepts of Maintenance
Release Certificates (MRC) and final CRS issued by a
Primary Maintenance Organisation (PMO) nominated
by the operator.
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WG 145.012: Single and multiple releases
Slide 12
European Aviation Safety Agency
Option 6: Key aspects
Initially, Option 6 consisted of:
Base Maintenance: An MRC issued by each organisation
and final CRS issued by PMO. Both MRC and CRS signed
by certifying staff.
Line Maintenance: At least 1 MRC per organisation for
each license category and final CRS issued by PMO. Both
MRC and CRS signed by certifying staff.
After further development to cover cases where there is
additional line maintenance performed after base
maintenance, Option 6 resulted in the following concept, as
proposed by the NPA (including a BMRC)
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Slide 13
European Aviation Safety Agency
Primary Maintenance Organisation
(PMO)
The Operator nominates a PMO (M.A.708(b)7 and AMC):
Base Maintenance: the organisation performing the majority of
maintenance (linked to number of tasks or man-hours or
number of affected systems). Should be the organisation with
the broadest view and control of the base maintenance event.
Line Maintenance: the organisation that will be responsible for
issuing the CRS.
Nomination may be included in the maintenance contract or in
the work order. It can be a long term agreement or single
event agreement.
Between two flights the operator may nominate one PMO for
base + line or one for base and another for line. It must be
clear. Only 1 PMO at each particular moment.
If the PMO is changed, the operator should provide the new
PMO all the necessary information regarding the previous
maintenance.
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WG 145.012: Single and multiple releases
Slide 14
European Aviation Safety Agency
Certification of aircraft maintenance
The certification of maintenance shall include
(145.A.50(a)):
Maintenance Release Certificates (MRC), and
Base Maintenance Release Certificate (BMRC), if
applicable, and
Certificate of Release to Service (CRS).
A key aspect is that a single CRS must be issued before
flight, ensuring to the pilot that the aircraft is ready for
service (always in relation to the maintenance ordered by
the operator, who retains the final responsibility for the
airworthiness of the aircraft and for contracting the
required maintenance)
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WG 145.012: Single and multiple releases
Slide 15
European Aviation Safety Agency
Maintenance Release Certificates (MRC)
(responsibilities)
The MRC is issued when: (145.A.50(b)(1)
and AMC)
The maintenance ordered to that organisation has
been properly carried out in accordance with Part145, and
The maintenance performed by contracted Part145 organisations has been coordinated and the
MRCs have been received, and
Outstanding defects and non-compliances have
been properly recorded and notified to the PMO.
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Slide 16
European Aviation Safety Agency
Maintenance Release Certificates (MRC)
(responsibilities)
Other aspects of the MRC:
The MRC does not imply that the aircraft is ready
for service.
Allows the certification of maintenance even if the
aircraft has been left in a non-approved
configuration (engine removed, crack found after
NDT, etc).
Not responsible for the work performed by
contracted Part-145 organisations nor for the
qualification of their personnel (they issue their
own MRC).
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Slide 17
European Aviation Safety Agency
Maintenance Release Certificates (MRC)
(who issues the MRC)
The MRC is issued by: (145.A.50(b)(1))
For Base Maintenance: An MRC issued by each Part-145
organisation, using:
 Category C certifying staff.
 Organisations other than PMO may use:
 B1/B2/A certifying staff if tasks performed under line
maintenance approval.
 NDT certifying staff for D1 rated organisations.
For Line Maintenance: At least one MRC issued by each Part145 organisation, using:
 B1/B2/A certifying staff.
 NDT certifying staff for D1 rated organisations.
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Slide 18
European Aviation Safety Agency
Maintenance Release Certificates (MRC)
(comparison with current system)
For Base Maintenance:
The MRC is similar to the current CRS issued by
each organisation in Base Maintenance.
For Line Maintenance:
The MRC is similar to the current CRS issued in:
 multiple release systems;
 single release systems prior to the issuance of
a final CRS.
It is also a flexible system because each
organisation can choose whether it issues one MRC
to cover all tasks or issues an MRC for each single
task.
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WG 145.012: Single and multiple releases
Slide 19
European Aviation Safety Agency
Maintenance Release Certificates (MRC)
(comparison with current system)
Similarly to the current CRS, each organisation issuing
an MRC takes full responsibility for the work performed.
The MRC allows the certification of maintenance also in
the following cases:
The organisation has received a Work Order that
leaves the aircraft in a non-approved
configuration (removal of engine, NDT inspection
which detects a crack out of limits….)
The organisation leaves uncompleted work to be
finished by another organisation.
In both cases non-conformances need to be recorded
and notified to the PMO.
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WG 145.012: Single and multiple releases
Slide 20
European Aviation Safety Agency
Base Maintenance Release Certificate
(BMRC) (responsibilities)
The BMRC is issued by the PMO when: (ref.
145.A.50(b)(2) and AMC)
All required MRCs have been issued, and
All the maintenance ordered by the operator in a
Base Maintenance event has been completed or
properly deferred, and
All activities were properly coordinated, and
There are no non-compliances which are known
that seriously hazard the flight safety.
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WG 145.012: Single and multiple releases
Slide 21
European Aviation Safety Agency
Base Maintenance Release Certificate
(BMRC) (responsibilities)
Other aspects of the BMRC:
The BMRC does not imply that the aircraft is ready
for service.
Proper coordination between organisations must
be ensured.
The PMO is not responsible for the work
performed by the other Part-145 organisations nor
for the qualification of their personnel (they issue
their own MRC).
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WG 145.012: Single and multiple releases
Slide 22
European Aviation Safety Agency
Base Maintenance Release Certificate
(BMRC) (who issues the BMRC)
The BMRC is issued by: (ref.145.A.50(b)(2))
Category C certifying staff of the PMO.
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WG 145.012: Single and multiple releases
Slide 23
European Aviation Safety Agency
Base Maintenance Release Certificate
(BMRC) (comparison with current
system)
Currently, in a pure single release system, a final CRS is
issued after Base Maintenance covering the CRS issued
by each organisation. However, it is not clear what
responsibility assumes the organisation who issues the
final CRS in relation to the work performed by the other
organisations.
In the proposed system the BMRC is issued after Base
Maintenance, without assuming the responsibility of
the work already certified by each MRC.
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WG 145.012: Single and multiple releases
Slide 24
European Aviation Safety Agency
Base Maintenance Release Certificate
(BMRC) (comparison with current
system)
Question: If the BMRC is equivalent to the current final
CRS after Base Maintenance, why we don´t call it CRS?
The reason is that there are cases where, after the Base
Maintenance is finished, there is a need to perform
additional Line Maintenance, even changing
organisations.
Nevertheless, the BMRC certifies that all the work
ordered in the Base Maintenance event has been
performed or properly deferred.
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WG 145.012: Single and multiple releases
Slide 25
European Aviation Safety Agency
Certificate of Release to Service (CRS)
(responsibilities)
The CRS is issued by the PMO when:
(145.A.50(b)(3) and AMC):
All required MRCs for Line Maintenance and the
BMRC for Base Maintenance, as applicable, have
been issued, and
All the maintenance ordered by the operator has
been completed or properly deferred, and
All activities were properly coordinated, and
There are no non-compliances which are known
that seriously hazard the flight safety.
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WG 145.012: Single and multiple releases
Slide 26
European Aviation Safety Agency
Certificate of Release to Service (CRS)
(responsibilities)
Other aspects of the CRS:
If the operator nominates a PMO responsible for
issuing the CRS different from the one that issued
the BMRC, the operator is responsible for
informing the new PMO about the maintenance
already performed and any possible conflicts with
the new maintenance to be performed.
The PMO is not responsible for the work certified
by the MRC´s and BMRC issued by other
organisations nor for the qualification of their
personnel.
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WG 145.012: Single and multiple releases
Slide 27
European Aviation Safety Agency
Certificate of Release to Service (CRS)
(who issues the CRS)
The CRS is issued by the PMO using: (ref.
145.A.50(b)(3))
Category B1 or B2 certifying staff (any of them),
or
Category C certifying staff when no line
maintenance has been performed after the
issuance of the BMRC.
Category A certifying staff when no Base
Maintenance has been performed and all the Line
Maintenance has been performed by this person.
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Slide 28
European Aviation Safety Agency
Conclusions
Appropriate coordination is ensured by the PMO, both
in Line & Base maintenance.
Each organisation issuing an MRC takes full
responsibility for the work performed and the
qualification of its personnel.
The BMRC certifies that all the work ordered in a
Base maintenance event has been completed or
properly deferred.
During a Base Maintenance event it is possible to
include also Line Maintenance Tasks, and cover all of
them within the BMRC.
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Slide 29
European Aviation Safety Agency
Conclusions
One single certificate can accommodate MRC, BMRC
and CRS.
Different types of Technical Log can be developed to
fit current existing systems:
Each maintenance action is issued an MRC, or
Each maintenance action is signed-off and one or
several MRCs are issued combining several tasks.
The system is very flexible and does not require to
assume responsibility for the work performed by
other organisations.
The system very clearly delimits the responsibility of
each organisation.
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WG 145.012: Single and multiple releases
Slide 30