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Continuing Airworthiness update
Juan AntonMaintenance Regulations Section ManagerFlight Standards DirectorateEASA
E&M Sub-SSCC02 June 2015
TE.GEN.00409-001
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Reg (EU) 1321/2014
Recast: repeals Reg (EC) 2042/2003 and amendments (“official consolidation”)
Published on 17th December 2014.
Entered into force on 6th January 2015.
The only new requirement Part-66 Appendix III: training shall comply with mandatory part of Operational Suitability Data (OSD). Application in art 6(3): type training courses approved before approval OSD shall include mandatory part not later 18 Dec 2017 or within 2 years (latest)
Contains reference to Reg (EC) 2042/2003 in the approval certificates.
Recast of Regulation 2042/2003 and upcoming Regulations (1/2)
7th Airworthiness Standardisation Meeting 2
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Opinions voted favourably in the EASA Committee in July 2014
Finalising the Scrutiny process
2 additional Regulations, amending the recast, are expected to be adopted 2nd quarter 2015
1st amending regulation includes:Changes linked to Part-M GA Phase I (Opinion 10/2013)
Changes to reg number in the approval certificates
Immediate applicability (20 days after publication)
Change of the date for the Opt-out to aircraft maintenance licenses for ELA1 not involved in commercial air transport, until 28 September 2015 2016
2nd amending regulation includes:Changes linked to ACAM opinion (Opinion 02/2013)
Changes linked to “critical tasks” opinion (Opinion 06/2013)
Changes linked to “alignment to BR” opinion. These are the changes from large aircraft to CMPA, changes to M.A.201 for the different types of operations, the new Part-T for dry lease of third country registered aircraft by licensed air carriers (Opinion 06/2012)
Applicability on 25 August 2016 with different opt-outs until 2017.
Recast of Regulation 2042/2003 and upcoming Regulations (2/2)
7th Airworthiness Standardisation Meeting 3
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Task 145.017 “Control of suppliers for components, parts and appliances”
Clarify the requirements and produce guidance on how to evaluate component suppliers.
Evaluate the possibility to use industry standards and accreditation programmes in order to reduce the auditing burden when a supplier is used by many maintenance organisations.
Opinion 12/2013 was published in December 2013.
This Opinion has not been discussed yet at the EASA Committee.
Opinion not voted yet
7th Airworthiness Standardisation Meeting 4
7th Airworthiness Standardisation Meeting 5
Draft Rulemaking Programme (1/3)
TASK NUMBER DESCRIPTION DELIVERABLE COMMENTS
TOR NPACRD/
Opinion
RMT.0135 (66.027 a) B2L and L licence X X 2015 Opinion 2Q 2015
RMT.0541Appendix I — Aircraft type ratings for Part-66
X X 2015Decision 2Q 2015 -Recurrent.
RMT.0245 (MDM.048)Standard aircraft changes and repairs
X X 2015 Decision 2Q 2015
RMT.0281 (MDM.082)New training methods/ New Teaching technologies
X X 2016 Opinion 1Q 2016
RMT.0393 (OPS.097 a) Maintenance check flights X X 2016 Opinion 3Q 2016
RMT.0276 (MDM.076) Technical records X X 2016Opinion 3Q 2016
RMT.0209 (M.014 a)Contracting of continuing airworthiness
X X 2016
RMT.0217 (M.029)CAMO and Part-145 responsibilities
X X 2017
RMT.0251 (MDM.055) SMS into 1321/2014 X X 2018
- Opinion 4Q 2015 (CAMO)- New NPA in 2017 with new approach ( Part-145, Part-147, POA, Section B )
RMT.0097 (145.024)Functions of B1 and B2 support staff
X X 2018
RMT in green more information in next slides (“recent”)
7th Airworthiness Standardisation Meeting 6
TASK NUMBER DESCRIPTION DELIVERABLE COMMENTS
TOR NPACRD/
Opinion
RMT.0547Task force for the review of Part-M for General Aviation (Phase II)
X 2016 NPA 2Q 2015
RMT.0521Review of airworthiness review process
X 2017 NPA 3Q 2015
RMT.0278 (MDM.078)Importing of aircraft from other regulatory systems
X 2017 NPA 4Q 2015
RMT.0106 (21.039 e)CS and GM for Maintenance certifying staff
X 2018 NPA 4Q 2015
RMT.0544 Review of Part-147 2018 NPA 4Q 2015
RMT.0537Privilege for CAMOs to issue Flight Conditions
2017 NPA 4Q 2016
RMT in green more information in next slides (“recent”)
Draft Rulemaking Programme (2/3)
7th Airworthiness Standardisation Meeting 7
TASK NUMBER DESCRIPTION DELIVERABLE COMMENTS
TOR NPACRD/
Opinion
RMT.0252 (MDM.056) sub 1
Instructions for continuing airworthiness (ICA)
X 2018 Certification
RMT.0252 (MDM.056) sub 2
Instructions for continuing airworthiness (ICA)
X 2018 Certification
RMT.0252 (MDM.056) sub 3
Instructions for continuing airworthiness (ICA)
X 2018Replaced by a certification procedure
RMT.0252 (MDM.056) sub 4
Instructions for continuing airworthiness (ICA)
X 2018 Certification
RMT.0252 (MDM.056) sub 5
Instructions for continuing airworthiness (ICA)
X 2018 Certification
RMT.0096 (145.023)Procedures for foreign Part-145 approvals
X XPut on hold in order to assess the feasibility to be continued
RMT.0255 (MDM.059) Miscellaneous of Part 66 X Task on hold
RMT.0243 (MDM.042) Major configuration differences XTask deleted — SIB to be issued.
RMT.0368 (MDM.091)Protection against the use of contaminated halon
Task deleted — SIB to be issued.
RMT.0211 (M.020) Recurrent defects on componentsTask deleted — SIB to be issued.
Draft Rulemaking Programme (3/3)
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Task RMT.0135 “Avionic licence for general aviation and licence for sailplanes, balloons, airships and ELA1 aeroplanes” (1/2)
B2L licence: this is a simplified avionics licence for all aircraft except those in Group 1 (the complex ones). This licence will be divided in the following system ratings:
Communication / Navigation
Instruments
Auto-flight
Surveillance
Airframe systems
L-licence: this is a very simple licence for the most simple aircraft. This licence covers:
sailplanes
powered sailplanes and ELA1 aeroplanes
balloons
hot air airships and ELA2 gas airships
gas airships above ELA2
Opinions/Decisions to be issued shortly
7th Airworthiness Standardisation Meeting 8
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Task RMT.0135 “Avionic licence for general aviation and licence for sailplanes, balloons, airships and ELA1 aeroplanes” (2/2)
NPA 2012-15. A total of 124 comments addressed in CRD 2012-15.
Opinion expected 2nd quarter 2015.
Introduces a change in dates in Article 8 “Entry into force” for the maintenance of ELA1 aeroplanes not involved in commercial air transport (to be discussed in EASA Committee),
(i) until 28 September 2018, the requirement for the competent authority to issue aircraft maintenance licences in accordance with Annex III (Part-66), as new or as converted pursuant to point 66.A.70 of the same Annex;
(ii) until 28 September 2019, the requirement to have certifying staff qualified in accordance with Annex III (Part- 66) contained in the following provisions:
M.A.606(g) and M.A.801(b)2 of Annex I (Part-M),
145.A.30(g) and (h) of Annex II (Part- 145).”
Opinions/Decisions to be issued shortly
7th Airworthiness Standardisation Meeting 9
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Task RMT.0245 “CS for standard changes and repairs”Allows the embodiment of “standard” changes/repairs on certain aircraft when defined conditions are fulfilled (without a design approval).
Document similar to the FAA AC 43-13 but replacing the field approval of the FAA system (which does not exist in Europe) by the release issued by Part-66 certifying staff.
Proposed NPA refers to certain repairs/changes included in FAA AC43-13 and in certain existing national documents.
NPA 2014-24 published in October 2014. 370 comments received.
Decision 2nd quarter 2015.
Phase II to develop further standard repairs/changes.
Opinions/Decisions to be issued shortly
7th Airworthiness Standardisation Meeting
Opinions/Decisions to be issued shortly
Task MDM.082 “New training/teaching technologies”
NPA 2014-22 published in September 2014.
Workshop performed in September 2014.
410 comments received
Most of the comments are favourable, but proposing simpler, better solutions, or better wording.
Many comments received (along with the proposals for change) on Appendix VII “Assessment method for multimedia-based training (MBT) systems” and the assessment table.
Two Review Group meetings in 2015
Opinion 1st quarter 2016
7th Airworthiness Standardisation Meeting 11
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Task RMT.0393 “Maintenance check flights”Issues addressed: Flight programme preparation, crew selection and qualification, personnel on board, interfaces with CAMOs, aircraft status. ELA1 and ELA2 aircraft excluded.
After the CRD 2012-08, some organisations have requested to change/remove the proposed experience requirements (number of Flight Hours) for the flight crew and to leave it more to the call of the operator (SMS / Performance Based Rules).
Coordination is being performed with the task RMT.0348 “Flights related to Design/Production” before issuing an Opinion 3rd quarter 2016
Opinions/Decisions to be issued shortly
7th Airworthiness Standardisation Meeting 12
Opinions/Decisions to be issued shortly
Task RMT.0276 “Technical records”The objective is to clarify the following:
Inconsistency in the use of terms such as “Life Limited Parts” and “Service Life Limited Parts”
Whether “Back to birth traceability” is needed.
Guidance on the use of electronic signature, the acceptability of scanned record copies and the use of new technology such as RFID (Radio Frequency Identification).
NPA 2014-04 was published in February 2014. 350 comments received. Two review group meetings in 2015. Some comments:
Time Controlled Components: definition and status including life accumulated by component
General aviation: consistency with work in Part-M GA (Phase II), summary entries in the logbooks
In-service history record for each Life Limited Part
Records keeping period
Opinion 3rd quarter 2016
7th Airworthiness Standardisation Meeting 13
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Task M.014 “Contracting of continuing airworthiness management activities”
To allow any CAT operators to contract its continuing airworthiness management to an external CAMO and remove the requirement to hold a CAMO approval themselves
Task is necessary to support the development of more efficient business models
NPA 2010-09 published in July 2010
Highly controversial task (total support from Industry, significant rejection from certain NAAs)
EASA will discuss the issue with dissenting NAAs
EASA will work on issuing an opinion in coordination with second phase of SMS, for consistency purposes, to be published in 2016
Opinions/Decisions to be issued shortly
147th Airworthiness Standardisation Meeting
Task MDM.055 “SMS embodiment and alignment with AR/OR requirements”
NPA 2013-01 published on 21 January 2013.
Covers Part-M and Part-145 (aprox 1300 comments)
NPA 2013-19 published on 10 October 2013.
Covers Part-147, -66 (aprox 190 comments)
The intention is to split the task:
Since Part-M is linked to the operator (OPS rules require SMS) – Opinion (covering only CAMOs) in 2015 based on the published NPA.
For Part-145, Part-147, POA, DOAs and Section B, there will be a new re-evaluation (and new NPA).
7th Airworthiness Standardisation Meeting 15
Opinions/Decisions to be issued shortly
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Task RMT.0547 “Task force for the review of Part-M for General Aviation (Phase II)”
Some expected features:
Light Part-M (new Annex VI to Reg (EU) 1321/2014). Organisation requirements (CAMO, Subpart F organisations) kept in Part-M;
Applicable to all ELA2 aircraft plus those helicopters certified for up to 4 occupants up to 1200 Kg MTOM, regardless of type of operation;
Owners/operators can choose to apply Part-M or Part-ML;
Defects Management:
Defect on non-required equipment may be deferred by the pilot,
Defect on required equipment to be deferred using MEL,
Other defect may be deferred by the pilot with the authorisation of the owner (only for non-commercial aircraft)
NPA to be published in 2nd quarter 2015
NPAs to be issued shortly
7th Airworthiness Standardisation Meeting 16
Task RMT.0521 “Review of the airworthiness review process”
Discussion on the following:Structure of the requirements
Need for and definition of controlled environment
Recommendations (as an intermediate step before the authority issues the ARC)
Independence from the airworthiness review process and from the maintenance release of the aircraft (AMC M.A.707(a)).
Sampling of documents during the airworthiness review
Content of the review
Open findings when issuing an ARC
Control of the airworthiness review process and prospective effects if more than one person is involved, including staff entitled to perform the airworthiness review and staff entitled to sign the ARC.
Transfer between Member States.
NPA expected 3rd quarter 2015
NPAs to be issued shortly
7th Airworthiness Standardisation Meeting 17
Task RMT.0278 “Importing of aircraft from other regulatory systems”
Objectives:Mitigate potential safety risks linked to the fact that the aircraft did not comply with the EU rules prior to being registered/imported, and to facilitate a common understanding of the approach to be followed, in terms of recognition of other certificates and/or records issued by other stakeholders to the aircraft involved,
Clarify current ambiguities in the rules related to issuance of CofA in order to achieve standardised implementation and equal treatment in all Member States.
NPA expected 4th quarter of 2015.
NPAs to be issued shortly
7th Airworthiness Standardisation Meeting 18
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Task RMT.0106 “CS and GM for maintenance certifying staff type rating training”
Main objective: improve the level of safety by requiring the applicant for a TC or Restricted TC for an aircraft to identify the minimum syllabus of maintenance certifying staff type training, including the determination of type rating.
This minimum syllabus, together with the requirements contained in Part-66, will form the basis for the development and approval of Part-66 type training courses.
NPA 4th quarter 2015
NPAs to be issued shortly
7th Airworthiness Standardisation Meeting 19
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RMT.0544 “Review of Part-147”Address the safety-critical issues as fraud by Part-147 organisations during basic examinations not linked to a basic training course
NPA 4th quarter 2015
NPAs to be issued shortly
7th Airworthiness Standardisation Meeting 20
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RMT.0537 “Privilege for CAMOs to issue Flight Conditions”
Draft ToR sent for comments
NPA 4th quarter 2016
NPAs to be issued shortly
7th Airworthiness Standardisation Meeting 21