Transcript Diapositive 1 - European Aviation Safety Agency

NPA 2007-08
Amendment to Part-M for
aircraft not used in
Commercial Air Transport
Juan Anton
13 September 2007
Czech Republic
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 (PartM, 145, 66 and 147). In particular, Part-M
introduces measures to be taken to ensure that
airworthiness is maintained, included maintenance.
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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, Part-M requirements are not applicable
yet (for countries that have opted-out), but its
implementation can not be postponed further than
28 September 2008.
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European Aviation Safety Agency
Part-M Regulatory Impact Assessment
and NPA 07/2005
Article 7(6) of (EC) No 2042/2003 required the
Agency to make an evaluation of the implications of
the provisions of Part-M.
Such evaluation was performed through NPA
07/2005, and the resulting CRD 07/2005 was
published on April 30th, 2007.
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European Aviation Safety Agency
Further changes to those proposed by
NPA 07/2005
Since Industry and NAAs had requested further changes to PartM (in addition to those from NPA 07/2005) in order to alleviate
the requirements imposed in non-commercial air transport
operations, especially on light aircraft, and since it was
necessary to develop Acceptable Means of Compliance (AMCs)
and Guidance Material, the Agency created Working Group
M.017. This group was also tasked to evaluate the comments
received through NPA 07/2005 and to develop CRD 07/2005, as
well as to evaluate maintenance related comments received
from MDM.032 “A better concept for General Aviation”.
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European Aviation Safety Agency
Further changes to those proposed by
NPA 07/2005
In addition to Working Group M.017, Working Group M.005 was
also created in order to address the issue of “Pilot Owner
Maintenance” and to produce a revised Appendix VIII that would
better adapt the needs of non-complex aircraft not involved in
commercial air transport. The concept of “jointly owning” an
aircraft has also been addressed.
THE RESULT OF THE WORK PERFORMED BY M.017 AND M.005 IS
THE NPA 2007-08 THAT HAS BEEN PUBLISHED AT THE END OF
JUNE 2007.
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European Aviation Safety Agency
Further changes to those proposed by
NPA 07/2005
During the work performed by Working Groups M.017 and
MDM.032, it was found necessary to study the possibility
of creating an aircraft maintenance licence specific for
light aircraft, the so-called "B3 aircraft maintenance
licence".
This task (called 66.022) has been undertaken by a subgroup of M.017 and is currently under discussion.
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European Aviation Safety Agency
Envisaged calendar
NPA 2007-08 has been published on 25 June 2007.
The comment period for CRD 07/2005 finished on 26 June 2007.
However, since some of the changes introduced have been
further developed by NPA 2007-08 (ARC issuance conditions,
Pilot Owner Maintenance….), it is the intention of the Agency not
to publish an Opinion following CRD 07/2005, and publish a
single Opinion by the 1st quarter 2008 covering both CRD
07/2005 and NPA 2007-08.
Consultation for NPA 2007-08 finishes by on 13 October 2007.
CRD expected to be published by December 2007, ending the
consultation period by February 2008.
Opinion (for CRD 07/2005 and NPA 2007-08) by March 2008.
Approval by the Commission hoped before June 2008, with
Decision on AMC and Guidance Material adopted immediately.
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European Aviation Safety Agency
Transitional measures
In view of the envisaged schedule:
Organisations will likely withhold their application for M.A.
Subpart F, Subpart G and Subpart I approval until the
envisaged changes are approved by the Commission.
Competent Authorities will probably not be able to complete
the corresponding investigations and issue the approval
certificates before 28 September 2008.
There will be a need to consider some transitional
arrangements which may include:
 Possible grandfathering measure to facilitate issuing of
approvals to organisations already performing similar
tasks under national regulations, and/or
 Postponing the entry into force of those provisions that
can not be reasonably implemented before 28 September
2008.
Such arrangements can not be elaborated until there is a
better view of the implementation difficulties.
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European Aviation Safety Agency
Transitional measures
As a consequence, the Agency has strongly encouraged the
Competent Authorities not to introduce provisions in their
national regulations that force the organisations to comply with
current Part-M requirements that are very likely to be amended.
This is further supported by the fact that both CRD 07/2005 and
NPA 2007-08 envisage the removal of the “12 month in a
controlled environment” requirement before a CAMO can issue
an ARC (after a full airworthiness review).
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European Aviation Safety Agency
Transitional measures
It is not the intention of EASA to propose postponing the entry
into force of the whole Part-M as a block as it is likely that more
proportionate measures may be a better way to address the
necessary transition from the national systems to Part M;
Such measures may include a phased introduction of particular
provisions of Part-M, based on supporting evidence from the
analysis of the comments received during the consultation of
NPA 2007-08;
They may also include grand-fathering provisions such as the
grant of Part M Subpart F (maintenance organisation) and/or
Subpart G (CAMO) and/or Subpart I (ARC privileges) approvals
to all organisations that have been granted a similar approval
under national rules, subject to some transitional conditions (see
the precedents in Regulations 1702/2003 and 2042/2003).
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European Aviation Safety Agency
Transitional measures
We therefore encourage regulated persons and competent
authorities to provide comments in relation to the particular
areas that may pose an implementation problem, together with
substantiation and proposals.
In order to accelerate the process, the Agency will review all
comments received as soon as possible, so the areas requiring
appropriate transitioning can be identified before the end of
2007.
We will also examine with National Aviation Authorities the
possibility to incorporate under national regulations provisions
of Part-M, Subparts F, G and I, together with the changes
proposed by NPA 2007-08, permitting voluntary organisations to
start the transition process without waiting for publication of the
amended regulation in the official journal.
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European Aviation Safety Agency
NPA/CRD 07/2005
NPA2007-08 (related to M.017)
Changes introduced in:
NPA/CRD 07/2005, and
NPA 2007-08 (related to M.017)
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European Aviation Safety Agency
Revision of Part-M versus “Light Part-M”
Feedback from Industry showed a preference for a separate
“Light Part-M”.
However, EASA did not find enough justification in doing so
because of the following reasons:
Most of the paragraphs of the current Part-M remain
unchanged. There is no need for duplication.
This duplication would have meant more inconsistencies and
duplicated work when keeping both documents updated
(including approval from the Commission).
Owners/operators trying to move from non commercial air
transport to commercial air transport would have needed to
learn two separate regulations, trying to identify the
differences between each other. This difference is much more
evident having a single regulation with some articles split in
commercial and non-commercial air transport (with an
appropriate weight limit).
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European Aviation Safety Agency
Changes not adopted (FAA AC 43-13)
Acceptance of FAA AC 43-13:
AC 43-13 states that its material can only be used for minor
repairs (no major repairs).
However, the decision (minor / major) has to be adopted by a
Part-21 design organisation (the outcome of MDM.032 may
facilitate it)
As a consequence, currently there is no legal basis to accept
the proposal.
A rulemaking task is going to start in 2008 to develop and
approve a document similar to AC 43-13.
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European Aviation Safety Agency
Changes not adopted (FAA 8130-3 issued
by non-Part-145 Repair Stations)
Acceptance of FAA 8130-3 issued by FAA Repair Stations not
approved in accordance with Part-145:
Components maintained prior to 28 September 2008 may be
issued a Form 1 (under the conditions of AMC M.A.613(a)).
Components maintained afterwards are not acceptable (not
allowed by the corresponding bilateral agreements).
The following considerations may reduce the impact:
 Reduce the number of components requiring a Form 1 or
equivalent, and also allow the owner to fabricate certain
non critical parts (under study by MDM.032).
 Such maintenance may also be performed by Part-145
organisations (which in many cases already exist).
 FAA repair stations may see a business case with the new
General Aviation market and get the Part-145 approval. It
is fairly easy and inexpensive (bilateral agreement)
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European Aviation Safety Agency
What is a "competent authority"
New AMC M.1:
A competent authority may be a ministry, an aviation
national authority or any aviation body designated by the
Member State.
A Member State may designate more than one competent
authority to cover different areas of responsibility (no
overlap of responsibilities).
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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.
CRD 07/2005 clarifies what is an "indirect approval
procedure" (M.A.302(b):
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, the maintenance programme and its
amendments are formally approved by the CAMO (no
need for competent authority endorsement).
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European Aviation Safety Agency
"Indirect Approval Procedure" of
maintenance programmes
NPA 2007-08 addresses the case where the State of
Registry is not the State responsible for the oversight of
the CAMO. (M.1 and M.A.302(b)):
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 they are different Member States, the responsibility
falls on the State of Registry, unless there is an
agreement between both countries. If there is no
agreement, the "indirect approval procedure" can not
be used on that particular aircraft.
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European Aviation Safety Agency
Maintenance programmes not linked to
an operator (independent CAMOs)
NPA 2007-08 introduces in M.A.302(c) the concept of
BASELINE and GENERIC maintenance programmes:
Purpose: permit the approval of the CAMO without
having any customer.
Only for aircraft not involved
Transport.
in Commercial
Air
Based on the maintenance programme recommended
by the TC holder.
"Baseline": for a particular aircraft type.
"Generic": to cover several similar aircraft types.
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European Aviation Safety Agency
Maintenance programmes not linked to
an operator (independent CAMOs)
AMC M.A.302 revised to include:
UK-LAMS is an example of "Generic" maintenance
programme.
"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 Form 14.
After the approval of the CAMO, these programmes
shall be revised to include specific tasks for each
customer (for each registration mark).
May be revised
procedure".
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through
the
"indirect
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approval
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European Aviation Safety Agency
Reliability Programmes
CRD 07/2005 clarifies in M.A.302(e) that a
Reliability Programme is not required for other than
large aircraft.
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European Aviation Safety Agency
Operator´s Technical Log
CRD 07/2005 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 in accordance with M.A.201(i).
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European Aviation Safety Agency
What is a work card / worksheet
Current Rule M.A.401(c):
The person or organisation maintaining an aircraft shall establish
a work card or worksheet system to be used and shall either
transcribe accurately the maintenance data onto such work cards
or worksheets or make precise reference to the particular
maintenance task or tasks contained in such maintenance data.
NPA 2007-08 amends AMC M.A.401(c):
For aircraft 2730 Kg MTOM and below these systems may take
the form of:
A format where the mechanic writes the defect, action and
maintenance data used,
An aircraft log book with the defect, action and maintenance
data used,
For maintenance checks, the checklist issued by the
manufacturer (i.e. 100h checklist).
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European Aviation Safety Agency
Component maintenance
NPA 2007-08 modifies M.A.502(b) and introduces new AMC
M.A.502 and AMC M.A.502(b) to clarify the following:
Component removal and installation from an aircraft is not
considered
component
maintenance,
but
aircraft
maintenance.
The normal requirement is that component maintenance must
be
performed
by
approved
organisations
(C
rated
organisations).
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 the
aircraft maintenance data describes or permits the
removal of such component.
In this case, the component can not be released with a Form
1, but in accordance with the aircraft release procedures.
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European Aviation Safety Agency
Control of unserviceable
components
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.
NPA 2007-08 amends AMC M.A.504(b) to clarify that:
A secure location may be any location described in the
procedures of the approved maintenance organisation for which
the organisation is responsible, and may include locations away
from the main maintenance facilities.
The purpose is to facilitate access to those locations to the
M.A.801(b)(2) certifying staff removing the component.
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European Aviation Safety Agency
Requirements for continued experience
of certifying staff
For
certifying
staff
in
Subpart
F
maintenance
organisations, the 6 months experience requirement in
every 2 years period has been changed to refer to the
experience requirements of Part-66, which in the case of
sailplanes and balloons refer to national rules.
This change also aligns with the requirement of
M.A.801(b)(2) that requires independent certifying staff
to be in compliance with the requirements of Part-66.
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European Aviation Safety Agency
What is a work order
Current Rule M.A.610:
Before the commencement of maintenance a written work order
shall be agreed between the organisation and the customer to
clearly establish the maintenance to be carried out.
M.A.610 has been revised in CRD 07/2005 to replace "customer"
by "the organisation requesting maintenance". "Organisation"
includes natural persons.
A new AMC M.A.610 has been added in NPA 2007-08 to clarify
that a "written work order " may be a formal document or a form
specifying the work to be carried out. This form may be provided
by the CAMO managing the aircraft, by the maintenance
organisation undertaking the work or by the owner/operator
himself.
An entry in the aircraft log book specifying the defect that needs
to be corrected also qualifies as a work order.
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European Aviation Safety Agency
Subcontracting of specialised services
(for Subpart F organisations)
Current Rule:
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.
NPA 2007-08 introduces in M.A.615 and associated AMC 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”.
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European Aviation Safety Agency
Qualification requirements of CAMO
nominated persons (and competent
authority personnel)
NPA 2007-08 amends AMC M.A.706 to clarify that the training on
aircraft types for the nominated persons in a CAMO should be at
least at Level 1 “General Familiarization” as specified in Part-66,
Appendix III and should cover at least one aircraft type for each
subcategory (i.e. helicopter piston, helicopter turbine, aeroplane
piston, aeroplane turbine) and for each type of turbine
propulsion system (turbofan, turboprop).
NOTE: Similar provision has been included in AMC M.B.102 for the
staff involved in Part-M activities within the Competent
Authority.
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European Aviation Safety Agency
Airworthiness Review Staff qualification
requirements for CAMOs (and Competent
Authorities)
NPA 2007-08 introduces in M.A.707 alleviated requirements for
organisations managing 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 provision has been included in M.B.902 for the staff
involved in Airworthiness Reviews within the Competent
Authority.
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European Aviation Safety Agency
Airworthiness Review Staff qualification
requirements for CAMOs (and Competent
Authorities)
NPA 2007-08 introduces AMC material in order 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.
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European Aviation Safety Agency
Airworthiness Review Staff qualification
requirements for CAMOs (and Competent
Authorities)
“Experience
M.A.707(a))
in
continuing
airworthiness”
means:
(AMC
Experience in tasks related to aircraft maintenance and/or
maintenance management (engineering) and/or surveillance
of such tasks, which may be combined.
NOTE: Similar provision has been included in AMC M.B.902(b) for
the staff involved in Airworthiness Reviews within the
Competent Authority.
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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))
Having authorisation to perform airworthiness reviews only
on aircraft which have not been managed by that person. For
example, performing airworthiness reviews on a specific
model line, while being involved in the management of a
different model line.
In the case of organisations with Subpart F, Subpart G and
Subpart I approval, maintenance personnel from the 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 continuing airworthiness
management organisation.
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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.
Having authorisation to perform airworthiness reviews only
on those particular aircrafts for which the person is
responsible for the complete continuing airworthiness
management process.
In the case of one-man organisation, this person has always
overall authority. This means that this person can be
nominated as airworthiness review staff.
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European Aviation Safety Agency
Airworthiness Review Staff qualification
requirements for CAMOs
For aircraft used in commercial air transport and aircraft above
2730 kg MTOM, formal aeronautical maintenance training means
training (internal or external) supported by evidence on the
following subjects: (AMC M.A.707(a)(1))
Relevant parts of continuing airworthiness regulations.
The operator’s Operations Specifications when applicable.
Relevant parts of the operator’s Operations Manual.
Relevant parts of operational requirements and procedures.
The organisation’s continuing airworthiness management
exposition.
Knowledge of a relevant sample of the type(s) of aircraft
gained through a formalised training course. These courses
should be at least at the Level 1 as specified in Part-66,
Appendix III and should cover at least one aircraft type for
each subcategory (i.e. helicopter piston, helicopter turbine,
aeroplane piston, aeroplane turbine) and for each type of
turbine propulsion system (turbofan, turboprop).
Maintenance methods.
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European Aviation Safety Agency
Airworthiness Review Staff qualification
requirements for CAMOs
For 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. This assessment should be recorded.
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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.
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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 for
each subcategory (i.e. helicopter piston, helicopter turbine,
rotorcraft, aeroplane piston, aeroplane turbine, gliders and
balloons), 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 the supervision of the competent
authority or, if accepted by the competent authority, under the
supervision of another currently valid authorised airworthiness
review staff of the concerned continuing airworthiness
management organisation in accordance with an approved
procedure.
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European Aviation Safety Agency
Airworthiness Review Staff qualification
requirements for CAMOs
AMC M.A.707(e):
The minimum content of the airworthiness review staff record
should be:
Name,
Date of Birth,
Basic Education,
Experience,
Aeronautical Degree and/or part-66-qualification and/or
nationally-recognized maintenance personnel qualification,
Initial Training received,
Type of Training received,
Continuation Training received,
Experience in continuing airworthiness and within the
organisation,
Responsibilities of current role in the organisation.
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European Aviation Safety Agency
Availability of maintenance data in a
CAMO
NPA 2007-08 has revised M.A.709 to indicate:
The approved continuing airworthiness management
organisation shall hold and use applicable current M.A.401
maintenance data in the performance of M.A.708 continuing
airworthiness tasks. In the case of customer provided
maintenance data, it is only necessary to have such data
when there is a contract with such a customer, with the
exception of the need to comply with M.A.714.
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European Aviation Safety Agency
Anticipation of the Airworthiness Review
M.A.710 allows the anticipation of the airworthiness review by a
maximum of 90 days without the loss of continuity of the
airworthiness review pattern, to allow the physical review to
take place during a maintenance check.
NPA 2007-08 has introduced new AMC M.A.710 to clarify that:
“Without loss of continuity of the airworthiness review
pattern” means that the new expiration date is set up one
year after the previous expiration date.
Renewal of the ARC must be for 1 year at least (even if the ARC
was expired)
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European Aviation Safety Agency
Privileges of the CAMO (removal of
“recommendations”)
M.A.711:
For aircraft of 2730 Kg MTOM and below , which are not used in
commercial air transport, CRD 07/2005 has removed the concept
of “recommendations” 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.
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European Aviation Safety Agency
Need for a Quality System
M.A.712:
The possibility has been added to have organisational reviews
even for organisations issuing ARCs for aircraft of 2730 Kg and
below. (CRD 07/2005)
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. (NPA 2007-08).
It has been stated that contracting continuing airworthiness
management tasks is not possible without a Quality System.
(NPA 2007-08)
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European Aviation Safety Agency
Need for a Quality System
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 persons in the CAMO
(including M.A.706 and M.A.707 personnel). (NPA 2007-08)
A new Appendix XII to the AMC has been created to give
guidelines on the content of the organisational reviews. (NPA
2007-08)
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European Aviation Safety Agency
Record-keeping
AMC M.A.714:
The M.A. Subpart G organisation should ensure that it
always receives a complete CRS from the approved
maintenance organisation and/or from the pilot owner
such that the required records can be retained. The
system to keep the continuing airworthiness records
should be described in the organisation continuing
airworthiness management exposition. (NPA 2007-08)
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European Aviation Safety Agency
Release authorisation in case of AOG
CRD 07/2005 removed this provision from M.A.607 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).
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European Aviation Safety Agency
Release authorisation in case of AOG
In the cases mentioned in the previous page, the owner shall:
obtain and keep in the aircraft records details of all the work
carried out and of the qualifications held by that person
issuing the certification, and
ensure that any such maintenance is rechecked and released
by an appropriately authorised M.A.801(b) person or a
Subpart F organisation or a Part-145 organisation at the
earliest opportunity but within a period not exceeding 7 days,
and
notify the contracted CAMO, or the competent authority in the
absence of such a contract, within 7 days of the issuance of
such certification authorisation.
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European Aviation Safety Agency
Release authorisation in case of AOG
AMC M.A.801(c):
“3 years maintenance experience” means 3 years working in
an aircraft maintenance environment on at least some of the
aircraft type systems corresponding to the aircrafts endorsed
on the aircraft maintenance license or certifying staff
authorisation that the person holds.
“Holding the proper qualifications” means holding either:

a valid ICAO compliant maintenance license for the aircraft
type requiring certification, or;

a certifying staff authorisation valid for the work requiring
certification, issued by a maintenance organisation
approved in accordance with ICAO Annex 6, Part II,
paragraph 8.1.3.
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European Aviation Safety Agency
M.A.901: Aircraft Airworthiness Review
Revised for aircraft of 2730 Kg MTOM and below which are not
used in commercial air transport. (CRD 07/2005 and NPA 200708):
Possibility for the owner to choose between a CAMO or the
Competent Authority.
Any CAMO appropriately approved (Subpart I) may be
contracted to issue the ARC (with full airworthiness review),
even if the aircraft has not stayed in a controlled environment
for the previous 12 months. So:
 The 12 month requirement has been removed.
 Maintenance can also be performed by M.A.801(b)(2)
certifying staff (except complex tasks per Appendix VII)
However, controlled environment still required for ARC
extension (without full airworthiness review).
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European Aviation Safety Agency
Part-M, Appendix I “ Continuing
Airworthiness Arrangement”
Included in Appendix I “Continuing Airworthiness
Arrangement”, the obligation of the owner to inform the
CAMO about the flying hours and any other utilization
data, as agreed with the CAMO. (CRD 07/2005)
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European Aviation Safety Agency
Part-M, Appendix II “ EASA Form 1”
Instructions have been revised to include some missing
information regarding the Release to Service (CRD
07/2005)
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European Aviation Safety Agency
Part-M, Appendix III “ Airworthiness
Review Certificate”
NPA 2007-08
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”
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European Aviation Safety Agency
Part-M, Appendix VII “ Complex
Maintenance Tasks”
NPA 2007-08

Appendix VII has been revised to incorporate complex
maintenance tasks related to piston engines.

The purpose of Appendix VII
that need to be performed in
organisation because they are
special tooling, equipment and
13 September 2007
is to provide those tasks
an approved maintenance
likely to involve the use of
facilities.
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European Aviation Safety Agency
Other provisions related to Part-M,
Section B (Competent Authorities)
NPA 2007-08

AMC material has been created to give flexibility to the
competent authority when creating the airworthiness survey
programme for aircraft for which it delivers the airworthiness
review certificate.

M.B.606, M.B.706 and AMC aligned with Part-145 (145.B.35)
regarding “changes”.

Editorial correction in AMC 704(b) regarding the time where back
credit for specific item audits can be granted (11 & 12 months
replaced by 23 & 24 months).
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