Airworthiness Policy Update - Civil Aviation Authority · 4 Rulemaking Part M Light Part CAMO (SMS)...
Transcript of Airworthiness Policy Update - Civil Aviation Authority · 4 Rulemaking Part M Light Part CAMO (SMS)...
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Topics for today
▪Rulemaking update for Part 145 & related
Part M
▪MOR update
▪Please ask questions as we go?
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Rulemaking – future changes (green)
Commission Regulation (EU) No 1321/2014
Annex I Part-MAnnex II Part-145
Annex III Part-66Annex IV Part-
147Annex Va Part-T Annex Vb –
Part-ML
Annex Vc
Part-CAMO
Annex Vd
Part-CAO
Cover Regulation
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Rulemaking
▪ Part M Light
▪ Part CAMO (SMS)
▪ Part CAO
▪ Agreement by the Member States on the proposed text
▪ Review by the Legal Services of the Commission before vote by the Member States
▪ Still ongoing due to issues raised by the Commission Legal Services
▪ No visibility of when the text could be finally voted by the Member States
▪ Not expected to be in force until early 2019
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Part T
▪From 25 Sept 2017
▪Part T approval required for the management of
third country aircraft leased in by a European
AOC holder
▪The CAMO will need to have their (Part T)
procedures approved before an AOC holder can
lease in an aircraft
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Part 145 change for Contracts
CAMO Contracts Part 145
when the CAMO is not appropriately approved to Part 145, the
organisation shall in consultation with the operator, establish a written
maintenance contract with a Part-145
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Sub-contracting
▪ Allows an unapproved organisation to carry out work under the Quality system of an Approved Maintenance Organisation
▪ Provides for specialised processes to be sub-contracted
▪ Such as painting – is it a specialised process?
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GR 10 Painting Revision July 17
▪ The task of painting an aircraft or making a change to its surface finish,such as paint removal and subsequent polishing, is a maintenance taskand consequently a CRS must be issued upon completion of theprocess.
▪ Simple repairs & minor touch up is considered line maintenancewhen conditions are appropriate
▪ A complex type must be controlled by an MRO that includes that type ontheir approval
▪ That MRO then paints the aircraft in its own painting facilities withapproval for the type and issues the CRS
▪ The most straight forward way – via a contract with the CAMO
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GR10 Painting continued
▪ When the Contracted 145 does not have an approved facility
to paint the specific aircraft type
▪ It sub contracts the painting task to an aircraft paint facility in
accordance with approved procedures
▪ As with all sub contracting the Part 145 MRO retains
responsibility for all work performed, that includes
▪ Facilities
▪ Tooling
▪ Equipment
▪ Data
▪ Competence of all staff involved in and overseeing the
paint task
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GR 10 - Finally
▪ Specialist painting organisations are not entitled to issue
any certification in respect of the airworthiness status of an
aircraft following painting, unless the organisation also holds
an appropriate ‘A’ rated maintenance organisation approval.
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Terminology/Changes in Part M/145
▪ A refresher on terms used now
▪ Licensed Air Carrier
▪ Complex Aircraft
▪ Part 145.A.48 addition with lots of AMC
▪ Critical Maintenance Tasks
▪ Identical Maintenance Tasks
▪ Tool Control
▪ Extraneous Material
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Occasional & Temporary Line Stations
– IN-2017/011
▪ Occasional – infrequent or irregular, of limited duration
▪ Limited to 10 consecutive days
▪ Does not include scheduled maintenance
▪ Process and procedures required
▪ Temporary
▪ Organisation audits prior to start
▪ CAA notified via SRG 1761 on website
▪ Process and procedures required
▪ In operation for a maximum of 6 months
▪ More than 6 months – permanent line station required
▪ Repetitive use at same location not permitted
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Rulemaking – update on 376/2014
Commission Regulation (EU) No 1321/2014
Annex I Part-M
Annex II Part-145
Annex III Part-66
Annex IV Part-147
Annex Va Part-T
Annex Vb -Part-ML
Annex Vc Part-CAMO
Annex VdPart-CAO
(EC) 216 ‘BASIC’ REGULATION
Cover Regulation
(EU) 376/2014
Commission Implementing Regulation (EU) 2015/1018
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Changes to the MOR System
▪ Audit will look for more than just a reference to 376/2014 and
ECCAIRS to comply
▪ 2015/1018 lists what to report for which sector (see flyer)
▪ Annex II of 2015/1018 relates to Technical Conditions, Maintenance
and the Repair of the Aircraft
▪ Design and Manufacture
▪ 18 items - Includes Life items not reaching their life limit
▪ 376 includes additional time limits regarding Safety Related items
▪ For Part 145 – not such a substantial change – 376 also includes
Voluntary Occurrence Reporting and Just Culture
▪ Confidentiality in accordance with National Law
▪ Analysis of both types of Report is required