Transcript Diapositive 1 - European Aviation Safety Agency

European Aviation Safety
Agency
Workshop EASA Part-M (aircraft not
involved in Commercial Air Transport)
Cologne
1 December 2006
Juan Anton
Cologne
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1. General
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European Aviation Safety Agency
REGULATION ORGANISATIONAL
STRUCTURE
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European Aviation Safety Agency
EASA: Rulemaking
Status of EASA texts
Applicability; basic principles and essential
requirements:

Binding; adopted by the legislator under co-decision; included
in Regulation
Implementing Rules:

Binding; will be adopted by the Commission following an
Opinion from the Agency
Guidance Material:

Not binding; adopted by the Agency.
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2. Part-M
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European Aviation Safety Agency
Regulation 2042/2003 Annex I
(Part-M) Entry into Force
Article 7(3)(a) to Commission Regulation
2042/2003 establishes that, Member States
may elect not to apply the provisions of
Annex I (Part-M) to aircraft not involved in
commercial air transport, until 28
September 2008.
See Opt-Out table:
(http://www.easa.europa.eu, Rulemaking,
Opt-outs to regulation)
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European Aviation Safety Agency
Structure of Annex I (Part-M) to
Regulation 2042/2003 Sections A&B
Part-M Section A
This section establishes the measures to be taken to ensure
that airworthiness is maintained. It specifies the conditions to
be met by persons or organisations involved in such
continuing airworthiness management or maintenance
organizations for general aviation.
Part-M Section B
This section establishes Administrative requirements to by
followed by the competent authorities in charge of the
application and enforcement of Section A.
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European Aviation Safety Agency
Who is the Competent Authority
(Paragraph M.1)
For the purpose of Part-M, the competent authority shall be:
For the oversight of the continuing airworthiness of individual
aircraft and the issue of airworthiness review certificates the
authority designated by the Member State of Registry.
For the approval of maintenance programmes, the authority
designated by the Member State of Registry.
For the approval and oversight of maintenance organisations
(Subpart F) and CAMO (Subpart G and I) the authority designated
by the Member State where they are located, except those based
in a third country. In this case, it will be EASA.
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European Aviation Safety Agency
Responsabilities of the owner and
Subcontracting (M.A.201)
The owner is responsible for the continuing airworthiness of
the aircraft and shall ensure that:
 The aircraft is maintained in an airworthy condition;
 Any operational and emergency equipment fitted is
correctly installed and serviceable;
 The airworthiness certificate remains valid;
 The maintenance of the aircraft is performed in
accordance with the approved maintenance programme.
The owner is responsible for granting the competent
authority access to the aircraft to determine continuing
compliance with Part-M.
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European Aviation Safety Agency
Responsabilities of the owner and
Subcontracting (M.A.201) cont’d.
 The owner may contract:
 The tasks associated with continuing airworthiness to an
approved continuing airworthiness management organisation
(CAMO) . In this case, the CAMO assumes responsibility for the
proper accomplishment of these tasks.
 The maintenance to an approved maintenance organisation
 However, for large aircraft and for operators requiring an
operational certificate (other than Commercial Air Transport), the
contract with the CAMO and with an approved maintenance
organisation is mandatory.
The Contract with the CAMO will comply with Appendix I.
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European Aviation Safety Agency
Responsibilities of the pilot in
command (M.A.201)
The pilot in command shall be responsible for the
satisfactory accomplishment of the “pre-flight inspection”.
The inspection must be carried out by the pilot or another
qualified person but need not be carried out by an approved
maintenance organisation or by a Part-66 certifying staff.
Pre-flight inspection is intended to mean all the actions
necessary to ensure that the aircraft is fit to make the
intended flight (see AMC M.A.301-1).
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European Aviation Safety Agency
Maintenance Programme
(M.A.302)
Every aircraft shall be maintained in accordance with a
“maintenance programme” approved by the competent
authority. It must be reviewed and amended accordingly.
When the aircraft continuing airworthiness is managed by a
CAMO the maintenance programme and its amendments
may be approved through a maintenance programme
procedure established by such organisation (indirect
approval). The procedure must be approved by the
authority.
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European Aviation Safety Agency
Maintenance Programme
(M.A.302)
The maintenance programme must be
established in compliance with:
TC holder recommendation

This only requires copying TC holder information but could
induce extra costs.
NAA recommendations

This will allow all existing national practices to continue,
such as LAMS (Light Aircraft Maintenance Schedule) in the
UK or AC extending piston engine overhaul limits.
Instructions defined by the owner

The owner may define himself other time limits acceptable
to the NAA. This will allow practices in force in certain
countries to continue in a more formalised manner.
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European Aviation Safety Agency
Modifications and Repairs
(M.A.304)
Modifications and repairs must be approved according to
Part-21.
EASA will work on publishing standards practices manuals
that will alleviate this requirement for the simple cases.
These documents will initially be based on FAA AC 43. 13.
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European Aviation Safety Agency
Aircraft continuing airworthiness
records (M.A.305)
For general aviation the existing
system of log books satisfies the
intent of this paragraph, as far as the
airworthiness records are concerned.
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European Aviation Safety Agency
Maintenance Standards/Maintenance
Data (M.A.401)
 The person or organisation maintaining the aircraft shall have
access to and use only applicable maintenance data in the
performance of maintenance including modifications and repairs.
 Maintenance data is:
 Any applicable requirement, procedure, standard or
information issued by the competent authority or the Agency.
This allows national systems to continue and enable EASA to
produce standards.
 Any applicable airworthiness directive;
 Applicable instructions for continuing airworthiness, issued by
type certificate holders, STC holders and any other
organisation that issues data in accordance with Part 21.
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European Aviation Safety Agency
Maintenance Standards/Performance of
Maintenance (M.A.402)
All maintenance shall be performed by qualified personnel,
following the methods, techniques, standards and
instructions specified in the Maintenance data.
PART-66 LICENCE IS NOT ALWAYS NEEDED
All maintenance shall be performed using the tools,
equipment and material specified in the maintenance data.
OWNERSHIP OF THE TOOLS IS NOT NEEDED
The area in which maintenance is carried out shall be well
organised and clean in respect of dirt and contaminations.
OWNERSHIP OF A HANGAR IS NOT NEEDED
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European Aviation Safety Agency
Subpart E Components
A Decision is very close to publication to declare as standards
parts all non required equipment on gliders.
Non salvageable parts must be mutilated beyond repair before
they are disposed of. This is important to limit the number of
bogus parts.
Maintenance on components must be performed by Subpart F or
Part 145 organisations. However, certifying staff qualified in
accordance with M.A.801(b)(2) may perform maintenance on
components while they are installed on the aircraft.
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European Aviation Safety Agency
Subpart F Maintenance Organisation
A maintenance organisation may maintain any aircraft and
or component which it is approved at the locations specified
in the approval certificate.
Alleviations for general aviation:
 No quality system. Organisational Reviews are allowed
per M.A.616.
 No ownership of tools, data and facilities.
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European Aviation Safety Agency
Subpart G Continuing Airworthiness Management
Organisation (CAMO)
An approved continuing airworthiness management
organisation may manage the continuing airworthiness of
non-commercial air transport aircraft as listed on the
approval certificate. The CAMO may be authorised to
approved the maintenance programme itself. The CAMO
may be approved to issue the airworthiness review
certificate.
Alleviations for general aviation:
 No quality system needed if no ARC privilege is held (for
small organisations)
 No ownership of data and facilities
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European Aviation Safety Agency
Certificate of Release to Service
(CRS) M.A.801
A certificate of release to service shall be issued before flight at
the completion of any maintenance by:
A Part-145 organisation;
A Subpart F organisation;
A Part-66 licensed engineer for non-complex tasks (see
Appendix VII), excluding components off the aircraft; For
gliders and ballons this means a national license.
A Pilot-owner (per Appendix VIII)
Tasks included in the AFM are not considered “maintenance
tasks”, except in those cases where there is an attachment
to the AFM showing the maintenance schedule.
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European Aviation Safety Agency
Certificate of Release to Service (CRS) by
the pilot-owner (M.A.803)
The pilot-owner is the person who owns or jointly owns the
aircraft being maintained and holds a valid pilot license with
the appropriate type or class rating.
For any privately operated aircraft of simple design with a
maximum take-off mass of less than 2730 Kg, glider and
balloon, the pilot-owner may issue the certificate of release
to service after limited pilot owner maintenance listed in
Appendix VIII to Part-M.
The limited pilot-owner maintenance shall be defined in the
aircraft maintenance programme.
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European Aviation Safety Agency
Certificate of Release to Service (CRS) by
the pilot-owner (M.A.803) cont’d
For a pilot-owner a certificate of release to service should
contain the following statement:
« Certifies that the limited pilot-owner maintenance except
as otherwise specified was carried out in accordance with
Part-M and in respect to that work the aircraft is considered
ready for release to service »
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European Aviation Safety Agency
Airworthiness Review Certificate
(ARC)
 To ensure the continued airworthiness of an aircraft an
airworthiness review must be carried out periodically. This
airworthiness review includes a review of technical
documentation and the physical survey of the aircraft.
 When an aircraft is continuously managed and maintained by
approved organisations this activity is carried out without the
intervention of the NAA.
 When an aircraft is not in the above case the ARC is issued by the
NAA based on a recommendation from a CAMO, every year.
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3. Significant Rulemaking
Tasks
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European Aviation Safety Agency
M.005: Pilot Owner Maintenance
Re-evaluation of M.A.803 and Appendix VIII.
Evaluate interface between Appendix VIII „Limited Pilot
Owner Maintenance“ and Appendix VII „Complex
Maintenance Tasks“.
Will incorporate the intent of Task M.010 regarding Pilot
Owner Maintenance in the case of collectively owned
aircrafts in flying clubs.
NPA to be published by 2Q 2007.
Opinion / Decision to be published by 2Q 2008.
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European Aviation Safety Agency
M.007: Part M amendment for noncommercial air transport.
Regulatory Impact Assessment performed by Air EuroSafe
to evaluate the impact of Part M.
Concern was limited to non-commercial air transport.
NPA07/2005 published on June 2005, with 5 months
consultation period.
CRD and Opinion / Decision will be issued by M.017 Task.
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European Aviation Safety Agency
M.017: EC2042/2003 amendment for
non-complex non-commercial aircrafts.
Takes over the review of comments from NPA07/2005
(M.007).
Implements the necessary changes to EC2042/2003 as a
result of MDM.032. Includes changes not only to Part-M but
to other Annexes (Part-66).
NPA to be published by 1Q 2007.
Opinion / Decision to be published by 1Q 2008.
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European Aviation Safety Agency
MDM.032: A concept for better regulation
in General Aviation
Implies changes to regulations related to Initial
Airworthiness, Continuing Airworthiness and
Maintenance, Air Operations and Pilot Licensing.
Changes to Continuing Airworthiness and
Maintenance are handled by M.017 group.
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European Aviation Safety Agency
THANK YOU FOR YOUR
ATTENTION.
www.easa.europa.eu
(new address)
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