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European Aviation Safety Agency Work Instruction Foreign Part 145 approval - Technical investigation Doc # WI.CAO.00004-002

Approval Date 14/07/2010

Foreign Part 145 approval – Technical investigation

WI.CAO.00004-002

Name Validation Date

Prepared by: Alessandro ZANUZZI Validated 14/07/2010

Verified by: Karl SPECHT Validated 14/07/2010

Reviewed by: Véronique MAGNIER Validated 14/07/2010

Approved by: Wilfried SCHULZE Validated 14/07/2010


of 33© European Aviation Safety Agency. All rights reserved. ISO9001 Certified.Proprietary document. Copies are not controlled. Confirm revision status through the EASA-Internet/Intranet.





DOCUMENT CONTROL SHEET

Reference documents

a) Procedures

PR.CAO.00001 - Foreign Part 145 approval

b) Internal documents

Log of issuesIssue Issue date Change description001 14/07/2010 First issue, Migration of S.I031-01002 01/09/2014 Update of Quality documents to implement the new corporate image of the

Agency and the changes to the organization structure.

0.INTRODUCTION

0.1 Table of contents

0. INTRODUCTION................................................................................................................. 30.1 Table of contents..........................................................................................................40.2 Definitions and Abbreviations.......................................................................................50.3 Scope........................................................................................................................... 60.4 Purpose........................................................................................................................ 60.5 Communication............................................................................................................60.6 General principles........................................................................................................6

1. Technical investigation.....................................................................................................71.1 Approval of the MOE in accordance with Part 145.B.25 & Part 145.B 40.....................81.2 Acceptance of Management Personnel in accordance with 145.A.30 (a) and (b).........9

1.2.1................................................................................................................................. 91.3 Acceptance of the Certifying Staff..............................................................................10

Line and base maintenance certifying staff....................................................................10Component certifying staff.............................................................................................10

1.4 Audit of a Part 145 Maintenance Organisation...........................................................111.5 Part 145 Audit report..................................................................................................121.6 Auditors’ qualification requirements..........................................................................12

2. Management of findings.................................................................................................132.1 Level 1 findings..........................................................................................................142.2 Level 2 findings..........................................................................................................152.3 Tracking and closure of Level 1 and Level 2 findings:................................................16

3. Recommendation of an approval....................................................................................173.1 Contact points when recommending an approval......................................................183.2 Recommendation package.........................................................................................19

Completion..................................................................................................................... 193.3 Quality check..............................................................................................................20

4. General time frames.......................................................................................................214.1 Time frame for an Initial Part 145 Approval................................................................224.2 Time frame for continuation of Part 145 Approval......................................................23

5. Administrative issues.....................................................................................................245.1 Team size & frequency of audit..................................................................................255.2 Working hours............................................................................................................265.3 Record keeping..........................................................................................................26

6. Forms............................................................................................................................. 276.1 EASA Form 6 Foreign..................................................................................................286.2 MOE/F4 Technical Visa (FO.CAO.00026-001)..............................................................286.3 Surveillance Plan (TE.CAO.00029-001).......................................................................286.4 Part 145 Appendix IV compliance check list (FO.CAO.00028-001).............................286.5 ICAO Annex I compliance check list (FO.CAO.00030-001)..........................................286.6 Emergency Part 145 level 1 finding notification form (FO.CAO.00027-001)...............28

7. User Guides....................................................................................................................297.1 UG.CAO.00005-000 “Foreign Part 145 approvals User guide for NAA / EASA”...........307.2 UG.CAO.00024-000 “Foreign Part 145 approvals - User guide for Maintenance Organisation Exposition”....................................................................................................307.3 UG.CAO.00006-000 “Foreign Part 145 approvals - User guide for Applicants............30

0.2 Definitions and Abbreviations AAM ADMINISTRATIVE ARRANGEMENT ON MAINTENANCE (TCCA/EASA)AAM-G ADMINISTRATIVE ARRANGEMENT ON MAINTENANCE GUIDANCEA&P APPLICATIONS AND PROCUREMENTS SERVICESAMC ACCEPTABLE MEANS OF COMPLIANCEAMO APPROVED MAINTENANCE ORGANISATIONBASA BILATERAL AVIATION SAFETY AGREEMENT (US/EUROPE)CAA CONTINUING AIRWORTHINESS AUTHORITY CAMO CONTINUING AIRWORTHINESS MANAGEMENT ORGANISATIONCAMOC CONTINUING AIRWORTHINESS MANAGEMENT OVERSIGHT COORDINATORCAN145 CANADIAN PART 145CAOM CONTINUING AIRWORTHINESS ORGANISATIONS MANAGERCAO CONTINUING AIRWORTHINESS ORGANISATIONC/S CERTIFYING STAFFCC/S COMONENT CERTIFYING STAFFDA DESIGNATED AUTHORITYEASA EUROPEAN AVIATION SAFETY AGENCYEASATL EASA TEAM LEADEREU EUROPEAN UNIONF145 FOREIGN PART 145F147 FOREIGN PART 147FAA FEDERAL AVIATION ADMINISTRATIONGM EASA GUIDANCE MATERIALMAST MAINTENANCE STANDARDISATION TEAMMIP MAINTENANCE IMPLEMENTATION PROCEDUREMIP-G MAINTENANCE IMPLEMENTATION PROCEDURE GUIDANCEMIST MAINTENANCE INTERNATIONAL STANDARDISATION TEAMMOA MAINTENANCE ORGANISATION APPROVALMOAP MAINTENANCE ORGANISATION APPROVAL PROCEDURESMOC MAINTENANCE OVERSIGHT COORDINATOR MOE MAINTENANCE ORGANISATION EXPOSITIONMOR MANDATORY OCCURRENCE REPORTING MTOA MAINTENANCE TRAINING ORGANISATION APPROVALMTOAP MAINTENANCE TRAINING ORGANISATION APPROVAL PROCEDURESMTOC MAINTENANCE TRAINING OVERSIGHT COORDINATORMTOE MAINTENANCE TRAINING ORGANISATION EXPOSITIONNAA NATIONAL AIRWORTHINESS AUTHORITYNAATL NAA TEAM LEADERPE PANEL OF EXPERTSTCCA TRANSPORT CANADA CIVIL AVIATIONUS145 US PART 145WG WORKING GROUPWHOC WORKING HOURS EASA OVERSIGHT COORDINATOR





0.3 ScopeThe CAO Section is responsible for managing the oversight of Part 145 Organisations based outside the EU Member States, the USA and Canada (hereafter referenced as “Foreign Part 145 organisation”).

This work instruction is complementary to the requirements of Implementing Rule - Regulation EU 2042/2003 Annex II, Part-145 and AMC “as amended” does not supersede or replace the information defined within this document.

0.4 Purpose The purpose of this work instruction is to assist the NAATL and the EASATL in the management of the “Technical investigation” for:

Initial approval Change of approval Continuation of approval

0.5 Communication All documents and correspondences between the Applicant, the overseeing authority and EASA shall be in the English language unless otherwise agreed by EASA.

0.6 General principles The Oversight of a foreign AMO could be either carried out directly by an EASA Team Leader or by an Accredited NAA. However EASA remains the competent authority responsible for the final approval and associated document as per section B of Part 145.

This work instruction:

Is therefore aimed to detail the procedure to be implemented by either EASATL, or NAATL when acting on behalf of EASA, on foreign 145 approvals. Where the process differs between EASATL and NAATL separate columns will be used.

Defines the various stages of initial, continuation, change, suspension and revocation of EASA approval certificates.

Provides a list of forms and associated user guides to be used when dealing with Foreign Part 145 approvals.

The forms, checklists and user guides addressed within the text and that have to be used by stakeholders are highlighted in green.The two last chapters of this Work Instruction provide:

a list of forms and checklist, a list of user guides





1.Technical investigation





1.1 Approval of the MOE in accordance with Part 145.B.25 & Part 145.B 40

Part 145 Requirement

EASA Accredited NAA

Part 145 B 25 §1AMC 145.B.25 (1) (§3)The competent authority shall formally approve Initial issue of the Exposition

The EASATL/NAATL verifies the compliance of the Exposition (including separated procedures and lists) with Part 145 requirements.When satisfied, he/she recommends the approval using “MOE/F4 Technical Visa - Form FO.CAO.00026-001” and sends it to the EASA MOC.The review of MOE should also include the associated procedures and lists when managed separately.

Part 145.B.40 (§1) & AMC 145.B.40Direct Approval of MOE amendments

The EASATL/NAATL verifies the compliance of the Exposition with Part 145 requirements.When satisfied, he/she recommends the approval using “MOE/F4 Technical Visa - Form FO.CAO.00026-001” and sends it to the EASA MOC.The review of MOE should also include the associated procedures and lists when managed separately.

EASAFormal MOE approval notification

The approval of the Exposition is formally notified in writing to the applicant by using the Letter F5 10 “Approval of MOE” . The relevant accredited NAA is copied in of the letter.The approval of MOE should also include the associated procedures and lists when managed separately.

Part 145 B 40 §2AMC 145.B.40Indirect Approval of MOE amendment

The indirect approval consists in the AMO Quality System approving documents in accordance with a procedure included to the MOE and therefore to be approved by the Authority.

The “indirect approval” privilege shall be based upon the NAATL or the EASATL confidence on the organisation structure and ability of the quality system to comply and remain compliant with the regulation.

This “indirect approval” cannot be granted at the time of the initial approval and in any case cannot be granted before the first 2 year period has been completed and found satisfactory.

Such a procedure for indirect approval can only apply to minor changes. The overseeing authority must receive a copy of such minor changes

when “indirectly” approved. As per AMC 145.B.40 (3) the NAATL or EASATL should acknowledge

receipt in writing of the amendment to the Organisation. EASA MOC shall be copied in.

Part 145 B 40 §2AMC 145.B.40 Verification that the MOE procedures comply with Part 145

The EASATL or the NAATL verifies that the procedures specified in the Exposition comply with Part 145 by using UG.CAO.00024-000 “Foreign Part 145 approvals - User guide for Maintenance Organisation Exposition” as reference material.





1.2 Acceptance of Management Personnel in accordance with 145.A.30 (a) and (b)

1.2.1Part 145

RequirementEASA Accredited NAA

145 B 20 §1 & AMC 145.B.20 (1) §1Formal acceptance of the management personnel

The EASATL/NAATL verifies the compliance of the Form 4’s with Part 145 requirements.When satisfied, he/she recommends the approval using “MOE/F4 Technical Visa - Form FO.CAO.00026-001” and sends it to the EASA MOC.

EASAFormal acceptance of the management personnel

The acceptance of the management personnel is formally notified in writing to the applicant by using the Letter F5 11 “Acceptance of nominated personnel” and by signing the Form 4s’. The relevant accredited NAA is copied in of the letter & F4s’

145 B 20 §4 & AMC 145.B.20(1) §2Acceptance of the Accountable Manager

Provided the requirements of Part 145.A.30 (a) are complied with, acceptance of the Accountable Manager is formalized by the approval of the Maintenance Organisation Exposition containing the Accountable Manager’s signed commitment.However the AMO may also provide an EAS F4 to demonstrate compliance of the Accountable Manager with the relevant Part 145 requirements.In any case when satisfied, he/she recommends the approval using the “MOE/F4 Technical Visa - Form FO.CAO.00026-001” and sends it to the EASA MOC.

EASAFormal acceptance of the Accountable Manager

The acceptance of the Accountable Manager is formally notified to the applicant by using the Letter F5 10 “Approval of MOE”. However when provided the F4 shall be signed and attached to the letter. The relevant accredited NAA is copied in of the letter.

145 B 35 & AMC 145.B.35Changes of Management Personnel

The EASATL/NAATL verifies the compliance of the Form 4’s with Part 145 requirements.When satisfied, he/she recommends the approval using “MOE/F4 Technical Visa - Form FO.CAO.00026-001” and sends it to the EASA MOC (1).

EASAFormal acceptance of changes of Management Personnel

The formal acceptance of changes of management personnel is notified in writing to the applicant by using the Letter “F5 11 “Acceptance of nominated personnel” and by signing the Form 4s’.

Note: The EASATL/NAATL should have adequate control established through the MOE procedure that they are timely informed by the Organisation of any change of the Management personnel.Note: According to paragraph Part 145.B.20 §4 the EASATL/NAATL shall hold a meeting with the Accountable Manager at least once during the investigation for initial approval to ensure he/she understands his/her responsibilities under Part 145. According to paragraph Part 145.B.30 (2) the Accountable Manager should be met minimum once during the 2 year surveillance cycle.Note: For any management personnel change the organisation shall supply EASATL/NAATL with an amendment to the MOE. The approval of the MOE shall be done according to paragraph. 1.1 of this work instruction.





1.3 Acceptance of the Certifying Staff.Line and base maintenance certifying staff

National License:When the compliance of the national licensing system with ICAO Annex I has not been yet evaluated (country not listed within the ICAO database) the EASATL or the NAATL shall verify such compliance during the initial investigation process. The document used to demonstrate the compliance shall be part of the recommendation package.Moreover the EASATL or the NAATL should verify every two year that the national licensing system remains in compliance with ICAO Annex I. If differences are reported, they must be notified to the EASA / MOC.

The check lists “FO.CAO.00030-001 - ICAO Annex I Compliance Check List” could be used as a tool for checking and recording the compliance with ICAO Annex I. The check lists “FO.CAO.00028-001 - Part 145 Appendix IV compliance Check List” could be used as a tool for checking and recording the compliance with Appendix IV of Part 145.

Type trainingAccording to Appendix IV:

“Line maintenance certifying staff and base maintenance support staff shall receive type training at a level corresponding to Part-66 Appendix III at level 3 for every A/C on which they are authorized to make certification”.

“Base maintenance certifying staff shall receive type training at a level corresponding to Part-66 Appendix III at level 1 for every A/C on which they are authorized to make certification”.

The EASATL or the NAATL shall use the “UG.CAO.00005-000 - Foreign Part 145 approvals - User guide for NAA/ EASA”. Paragraph « Instruction for Certifying Staff / Support Staff assessment» when:

validating and auditing the procedures related to certifying staff/ support staff qualification within the MOE

sampling the certifying staff files during the continued surveillance or reviewing the certifying staff list.

Component certifying staffComponent certifying staff shall comply with Part-66. EASA Part-66 specifies in paragraph 66.A.200; “Until such time as this Part specifies a requirement for certifying components, the relevant Member State Regulation shall apply”.This means that any relevant EU Member State Regulation for component certifying staff can be used.However when a foreign Part 145 organisation is nominating component certifying staff the exposition shall describe the procedure of qualification. This procedure shall at least comply with the requirements as detailed in the paragraph «Component Certifying Staff» of the “UG.CAO.00005-000 - Foreign Part 145 approvals - User guide for NAA/ EASA”.





1.4 Audit of a Part 145 Maintenance Organisation.As soon as the draft of the MOE, the EASA Forms 4, the associated documents, the Quality Assurance Manager statement, the audit report if requested, are deemed acceptable, the accredited NAATL or EASATL initiates the on site investigation in accordance with Section B of Part 145, its associated Acceptable Means of Compliance (AMC) / Guidance Material (GM) and Internal CAO procedures and work instructions.

EASA Accredited NAAPreparation The audit plan should be prepared by the Auditor/Team Leader by taking into account

the available resources (audit team) and the scope of work of the Organisation. The plan should establish compliance against the particular regulation and the current MOE revision by auditing a cross section of the Organisation’s activities. The audit plan should be notified to the Organisation.For initial approvals and changes of approval, a Statement signed by the Organisation Quality Assurance Manager shall always be provided before the audit takes place confirming that processes, facilities, documentation, tools and personnel subject to the application have been reviewed and audited showing compliance with all applicable requirements. The relevant audit report shall be requested by the EASATL/NAATL.The following points should be considered when preparing the audit plan:

o Any follow-up actions from previous audits where necessary;o Dates and places where the audit activities are to be conductedo Audit scope, including identification of the organisational and functional units

and processes to be audited;o Quality Assurance Manager Compliance Statement and when requested the

audit reporto Expected time and duration of audit activities, including meetings with the

auditee’s management and audit team meetings.Achievement

An opening meeting will be held with the auditee’s management. The following points should be considered when carrying out the meeting:

o Confirmation of the audit schedule (including the scope of the audit).o Explanation on the method used for reporting nonconformities and dealing with

Level 1 finding.All information relevant to the audit objectives, scope and criteria will be collected by appropriate sampling (through interviews, observation of activities, review of documents and records) and verified. It is therefore understood that only verifiable information will be recorded as audit evidence.The audit evidence will be evaluated against the audit objective and references in order to determine findings. The audit team will review the findings at appropriate stages of the audit with the auditees in order to prevent any future misunderstanding. All non conformities and their supporting evidence must be recorded where applicable to allow traceability.Prior to the closing meeting, the audit team shall review the audit findings and evidence collected against the current/intended scope of approval, agree on level* and time scales and prepare the audit conclusions to be presented.A closing meeting, chaired by the audit Team Leader will be held to present the audit findings and conclusions to the auditees in order to ensure that they are understood and accepted. The auditee will be given the opportunity to discuss any non-compliance identified. Corrective actions and an acceptable timeframe for implementation could be also discussed.

* Classification of Level 1 findings is subject to prior confirmation by the EASA MOC or EASA DA (See the relevant paragraph of this W.I.)NOTE: Any finding discovered during the audit must be debriefed to the Organisation. No finding could be added to the audit report that has not been debriefed to the Organisation.NOTE: During the audit of the organisation the EASATL or the NAATL will crosscheck the number of technical staff as detailed within the MOE and the EASA Form 2. He/she will identify any inconsistency with the number of staff required to meet the manpower requirements of the approval scope and rating as detailed in EASA Part-145.A.30 and the manpower aspects of Part 145.A.30 (d) and as detailed in the approved MOE. The EASATL or the NAATL shall notify EASA MOC of such





inconsistencies.Note: For an initial audit the findings should not be classified as Level 1 or 2 as no action can be taken against the certificate.

1.5 Part 145 Audit report

EASA Accredited NAA

Audit form: The report form to be used by the EASATL/NAATL is the EASA Form 6 Part 4 “Findings Part 145 compliance status”.

Or NAAs could use their own report form for intermediate audits provided no Level 1 finding has been raised.

Intermediate audit

The recommending authority shall copy in the EASA MOC with all intermediate audit reports sent to the AMO.

Additional audit report

The EASATL could additionally complete a narrative of the areas audited (in line with normal practice) and will show the areas reviewed, the examples checked and where found in compliance. The form of this additional document is at the auditors’ discretion but can be hand written notes (if legible) or a typed report.

The NAATL could additionally complete a narrative of the areas audited (in line with normal practice) and will show the areas reviewed, the examples checked and where found in compliance. The form of this additional document is at the NAAs’ discretion provided it is described in their procedures

Notification letter

The audit report is transmitted to the applicant together with the Letter F5 12a or 12b “notification of audit findings”.Even when no finding has been raised, a notification letter should be sent to the organisation.

The process and support used to transmit the audit report to the applicant is at the NAAs’ discretion provided it is described in their procedures.

Notification letterin case of Level 1 finding confirmed by EASA

In case of confirmed level 1 finding, the EASATL/NAATL shall NOT transmit to the Organisation the audit report, but relevant Form 6 recommendation filled in all its Parts to the EASA MOC /DA.EASA will notify the finding(s) to the Organisation together with the decision against the approval. As audit report, the EASA Form 6 – Part 4 is attached to this notification.

Time frame for generating the Audit Report

The audit report is normally produced at the time of completion of the audit.The formal notification of the findings must be sent to the Organisation within a maximum of 15 calendar days from the end of the audit except in case of level 1 findings where the audit report is to be sent out by EASA.Only those findings discussed and agreed with the Organisation before departure can be included in the report as non-compliances.

1.6 Auditors’ qualification requirements

EASA Accredited NAAAuditor’s Qualification requirements

Each auditor should comply with Section B of the relevant Annexes to the Regulation EC 2042/2003.EASATL shall hold and carry a valid “Authorisation for Inspection Letter” (TE.CAO.00008.001) with him/her when performing an investigation.

Each auditor should comply with Section B of the relevant Annexes to the Regulation EC 2042/2003. The qualification requirements defined by the NAA must be developed in its procedure. The auditor should have been qualified according to this procedure and should carry with him/her the proof of the qualification /authorisation when performing investigations on behalf of





EASANote: The qualification criteria shall include knowledge and experience of auditing techniques, as well as theoretical knowledge and practical experience in the relevant technical matters covered by the relevant Annex to the Regulation EC 2042/2003 and subsequent amendments.

2.Management of findings





2.1 Level 1 findingsEASA Accredited NAA

Level 1 finding:In case a significant non-compliance with any applicable requirement of (EC) Regulation 2042/2003 Annex II and subsequent amendments which lowers the safety standard and hazards seriously the flight safety is identified, the Inspector must follow the following steps:1. Information to EASA:He/she immediately inform EASA (MOC, CAOM or the Head of Department) by any available means of communication (phone, e-mail, fax).

CASE 1: In the case that the audit takes place during normal working hours of the office in Cologne the assigned inspector should contact EASA using the following contact details:

Mr Marc Gragnoli (EASA MOC)Email: [email protected] jean-yves [email protected] Tel : +49 221 89 990 4151Fax : +49 221 89 990 4651

Mr Karl Specht (CAOM)Email: [email protected](copy jean-yves [email protected]) Tel : +49 221 89 990 6047Fax : +49 221 89 990 6547

CASE 2: In the case the audit takes place outside normal working hours of the office in Cologne due to time differences and weekends, the assigned inspector- through the NAA/QE MOC where possible- should contact EASA by using the following contacts details:

Telephone : +49.170.782.3417E-mail address: [email protected]

This number is being distributed to the NAAs, Air Accident Investigation Boards, major manufacturers and certain other Organisations to enable them to contact the Agency in an emergency. It is not to be used as a general phone number. The dedicated email address functions 24 hours per day, the telephone line, however, is operational Monday to Friday from 5.00 p.m. to 8.00 a.m. the next day) and 24/24 over the weekend or on public holidays.

2. Information to the organisationAs soon as the assigned inspector identifies a serious safety concern that she/ he feels is possibly a level 1 finding, the organisation must be briefed accordingly explaining that the EASA confirmation is needed prior to formal notification of the level 1 finding.3. Finding description and EASA confirmationThe assigned inspector shall use the “Emergency Part 145 level I finding notification Form - FO.CAO.00027-xxx” to describe and notify the proposed level one finding to EASA.EASA will use the same document to formally notify the final finding classification back to the assigned inspector.4. Debrief to the organisationOnce the EASA confirmation is received the assigned inspector should orally brief the Organisation accordingly.5. Audit reportIn case of potential level 1 finding (confirmed or not), the assigned inspector shall NOT transmit to the Organisation the audit report. EASA will notify the finding(s) to the Organisation together with the decision against the approval.6. F6 RecommendationThe assigned inspector shall transmit the relevant Form 6 recommendation filled in all its Parts, via the NAA/QE MOC, to the EASA MOC. The Part 5 shall also include the recommendation regarding the certificate.7. Notification to the organisationThe Agency is the competent authority for foreign Part 145 approvals and as such shall take any action in respect to the approval. In case of confirmed level 1 finding EASA will notify the finding(s) to the Organisation together with the decision against the approval. The EASA Form 6 – Part 4 will be used as audit report and be attached to this notification.

mailto:[email protected]

mailto:jean-yves

mailto:jean-yves


mailto:jean-yves

mailto:jean-yves

mailto:%[email protected]





2.2 Level 2 findingsEASA Accredited NAA

Level 2 finding

Level 2 finding:When any non-compliance with any applicable requirement of (EC) Regulation 2042/2003 Annex II and subsequent amendments which could lower the safety standard and possibly hazard the flight safety is identified, the EASATL or the NAATL should notify the Organisation in writing according to the relevant Part and the paragraph 2.4 “notification report” of this work instruction.

The corrective action period granted by the EASATL or NAATL must be appropriate to the nature of the finding but in any case initially must not be more than three months.

Note: For an initial Audit the findings should not be classified as Level 1 or 2 as no action can be taken against the certificate. They should however still be tracked to ensure they are closed before the recommendation is made. A maximum of three months shall be allowed to take corrective action for each finding raised during the initial audit. Failure to close these findings during this three months period could lead the Agency to terminate the application.





2.3 Tracking and closure of Level 1 and Level 2 findings:The NAATL or the EASATL is responsible for tracking the implementation of the corrective action(s).

EASA Accredited NAA

Tracking of corrective actions

It is the responsibility of the EASATL or the NAATL to manage both level 1 & 2 finding due dates and also any additional limits imposed by EASA that are addressed in the notification letter.In case due dates are reached without any acceptable actions from the AMO, the EASATL or the NAA MOC shall inform the EASA MOC.

Closure of the audit report which includes level one finding

When the EASATL or the NAATL is satisfied with the corrective actions that have been proposed by the Organisation in respect of finding(s) raised during the audit, he/she notifies in writing the organisation together with the EASA MOC that the proposed corrective actions are considered to be acceptable.The final closure of the report is subject to an in situ re-instatement audit to confirm the proper implementation of the corrective actions.

Once the EASATL or the NAATL is satisfied with the implementation of the corrective action, he/she responsible for recording the reference of the corrective actions and the date of closure in the re-instatement EASA Recommendation Form 6.

Closure of the audit report which does not include level one finding.

When the EASATL is satisfied with the actions that have been taken by the Organisation in respect of the finding raised during the audit, he/she notifies the Organisation (in writing) that the non compliances are considered to be closed by using the Letter F5 13 “Closure of non-compliances”. In the mean time the EASATL is responsible for recording the reference of the corrective actions and the date of closure in the EASA recommendation Form 6 – Part 4.

When the NAATL is satisfied with the actions taken by the Organisation in respect of the finding raised during the audit, he/she should notify the Organisation that the non compliances are considered to be closed. The document used is at the NAAs discretion provided it is described in their procedures. Additionally the NAATL is responsible for recording the reference of the corrective actions and the date of closure in the audit report. .

Note: Any extension of delay related to level 2 finding should be justified and sent in writing by the Organisation to the EASATL or NAATL. The EASATL or NAATL shall notify his/her decision to the Accountable Manager and record such an extension in the Audit report.Such an extension should not be systematically granted (AMC 145.B.50 (b1)). Before extending the initial period the authority must be satisfied with a corrective action plan provided by the AMO.Note: According to Part 145.B.50 (b), when the Organisation cannot meet the timescales specified for Level 2 finding and did not request any extension, the EASATL or the NAATL should inform the EASA MOC who will take together with the CAOM the decision to re-classify the Level 2 finding to Level 1 with the associated decision related to the approval (suspension, limitation).Note: The follow-up system used to track that the Organisation meets the timescale specified for finding corrective action is at the NAAs’ discretion provided it is described in their procedures.





3.Recommendation of an approval





3.1 Contact points when recommending an approval

The initial application and the application for change are directly sent to EASA by the applicant. EASA is responsible for passing the application package to the allocated NAA (MOC) or the EASATL in order to proceed with the investigation process. Once the investigation process has been carried out, the NAA MOC or the EASATL is responsible for providing the EASA MOC with the recommendation package.

Within EASA the assigned person (EASA MOC) who manages the Foreign Part 145 projects is Marc Gragnoli [email protected]

When sending a recommendation package the NAA MOC should address it to both the EASA MOC and the administrative assistant Mrs. Beatrice Prijot. [email protected]

The responsibilities associated to the Part 145 DA may be carried out by all EASA CAO Team Leaders.

The EASA MOC/DA is the focal point for NAAs for all topics related to Foreign Part 145 Organisations.The NAA MOC/DA is the focal point for EASA. In extenuating circumstances a NAA TL may have to contact directly the EASA. In such case and after his acceptance the NAA MOC/DA should be copied in all related correspondences.







3.2 Recommendation packageCompletion

The accuracy and completeness of the recommendation package is essential to issue an approval based upon full confidence in the recommendation. It is imperative that all the documents submitted to the Agency are thoroughly checked before submission by authorized staff. Only the EASA Forms as detailed in the CAO section procedures have to be used when providing a recommendation for foreign Part 145 approval.

An EASA Recommendation package shall be completed: For the initial issuance of an approval (recommendation for initial approval). For each change of approval (recommendation for change). Every 24 months (recommendation for continuation of approval). For a suspension/revocation when a Level 1 finding is raised. For reinstatement of approval after suspension/limitation.

a) The recommendation package for an Initial application should contain :o the signed recommendation EASA Form 6o the signed MOE /F4 Technical Visao EASA Form 4 (s) o a copy of the MOE chapters 1.7 “manpower resources”, 1.9 “scope of approval”,

5.3”list of Line maintenance locations”. o the Form 3 template certificateo a copy of the Form2o the surveillance plano the organisation QAM statement.o a copy of the initial compliance document of the national licensing system with the

ICAO Annex I requirements (as necessary).

b) The recommendation package for a change of approval should contain :o the signed recommendation EASA Form 6o a copy of the Form2 (+ copy of the C of I if name change)o the organisation QAM statemento the signed MOE /F4 Technical Visao EASA Form 4 (s) (as necessary)o a copy of the MOE chapters 1.7 “manpower resources” 1.9 “scope of approval”, 5.3

”list of Line maintenance locations”o the form 3 template certificate (as necessary)o the surveillance plan (as necessary)

c) The recommendation package for a continuation of approval should contain :o the signed recommendation EASA Form 6o the surveillance plano a copy of the continued compliance document of the national licensing system with

the ICAO Annex I requirements.

d) The recommendation package for a suspension/revocation of approval should contain :

o the signed recommendation EASA Form 6o the form 3 template certificate (as necessary)o the surveillance plan (as necessary)

e) The recommendation package for a re-instatement of approval should contain :o the signed recommendation EASA Form 6o the organisation QAM Statemento the signed MOE /F4 Technical Visa (as necessary)o EASA Form 4 (s) (when necessary)o a copy of the MOE chapters 1.7 “manpower resources” 1.9 “scope of approval”, 5.3

”list of Line maintenance locations”o the form 3 template certificate (as necessary)o the surveillance plan (as necessary)





When using the Template FORM 3 to recommend the scope instead of using part 5 of the Form 6, a cross reference between both documents must be recorded.

3.3 Quality check The recommendation package shall be checked for completeness and accuracy (quality check) by an authorized person and then sent to EASA MOC for review:

EASA Accredited NAA

Authorised person

When the EASA elects to oversee the Organisation, only the EASA MOC /DA are authorised to perform the quality review within the CAO Section.In the case of their absence, the CAOM performs the quality check.

When the investigation is carried out by an accredited NAA, only the MOC or the person identified and authorised according to the National procedure can carry out the quality check.

The quality review includes the checking of the following:

The completeness of EASA FORM 6 (all 5 parts) The completeness of EASA MOE /F4 Technical Visa (as necessary) MOE Issue/Revision status Corrective action plan addressed when there are open findings. EASA Form 4s MOE chapter 1.7 “manpower resources” and chapter 1.9 “scope of approval” (as necessary). The continued surveillance plan The consistency of the EASA Form 2 with the MOE (“number of staff” & “scope of approval”),

EASA Form 6 and the technical visa Availability of document showing the initial / continued compliance of the national licensing

system with the ICAO Annex I requirements (as necessary) Availability of the organisation QAM Statement (as necessary)





4.General time frames





4.1 Time frame for an Initial Part 145 Approval





4.2 Time frame for continuation of Part 145 Approval





5.Administrative issues





5.1 Team size & frequency of audit

EASA Accredited NAA

Determination of the team size

Normally, one auditor is to be used unless otherwise agreed by EASA.All cases where more than one auditor is to be used must be justified by the NAA MOC and agreed by EASA prior to the investigation taking place.The criteria that will be applied by EASA to determine the investigation team (more than one auditor) are as follows:

o Complexity of the organisation approvalo Number of sites to be auditedo Type of audit (initial, changes, follow up audits, findings etc.)o Size of the organisationo Nature of the services to be covered by the AMO and its direct

impact to aviation safetyo Appropriate technical experts (may include language needs)o Any additional reason deemed necessary by EASA and justified by

a specific situationIf an accredited NAA elects to use additional staff or trainees for an audit, EASA must be informed in advance. In all such cases any associated costs shall be borne directly by the NAA and not by the applicant or EASA.Trainee staff from EASA may participate in investigation teams at no direct cost to the applicant.

The agency shall allocate man-hours for the oversight of each project. In all cases, where the numbers of man hours are going to be exceeded, the EASATL or NAA MOC shall provide justification for additional hours.

Frequency of audits

Normally the frequency shall be one visit per year referring to the Surveillance Cycle.This implies that:

o A first intermediate audit should be carried out between 6 months and 12 months from the date the certificate was granted;

o The second intermediate audit should take place between 12 and 24 months from the date of the certificate was granted;

o The NAA should ensure that a period of minimum 6 months and maximum 18 months between each audit is maintained - never exceeding 24 months from the date the certificate was granted. However the NAA should try to maintain where possible an interval of 12 months between two intermediate audits.

The frequency of audit may be increased when agreed by the EASA MOC /DA.The criteria to be reviewed by the EASA MOC for increasing audit frequency are as follows:

o Follow up of audits / findingso Change to approvalo Incident responseo Request by the Agencyo Large complex Organisationo Number of aircraft/aircraft type managed by the Organisation

The frequency of audit of Line stations is detailed in the paragraph “Instruction for foreign Part 145 Line station “of the“UG.CAO.00005-000 - Foreign Part 145 approvals - User guide for NAA/ EASA”.





5.2 Working hoursA number of working hours is allocated by the Agency for the management of applications and approvals on its behalf. The allocation of working hours process is detailed in the paragraph «allocation of technical working hours » of the UG.CAO.00005-000 “Foreign Part 145 approvals User guide for NAA / EASA”

5.3 Record keepingAs detailed in Part 145.B.55 (3) the period of retention of records associated with the process of issue, change, continuation, suspension, revocation of an Organisation approval is at least 4 years.

Part 145 Requirement

EASA Accredited NAA

145.B.55 (1) (3)AMC 145.B.55

The competent authorities shall establish a system of record-keeping that allows adequate traceability of the process to issue, continue, change, suspend or revoke each certificate.

A scanned copy of : The application package:

o FORM 2o Certificate of Incorporation, etc.).

EASA correspondences:o Letterso template letterso EASA FORM3

The recommendation package received from the EASATL or NAATL

o Formso EASA Form 6o MOE /F4 Technical Visao Form 4s’o EASA Surveillance Plano Additional audit reportso QAM statement

are archived on the V:\ drive in the relevant Organisation electronic file according to the internal Work Instruction DRM.00017-001 “CAO records management”.The EASATL is responsible to archive the successive MOE and associated documents on the V:\ drive in the relevant Organisation electronic file according to the internal Work Instruction.CAO Section administration staff is responsible to keep the approvals’ electronic files up to date.

The process of record keeping is at the NAAs’ discretion provided it complies with Section B of the relevant 2042/2003 Annex II and it is described in their procedures.







6. Forms







6.1 EASA Form 6 Foreign 6.2 MOE/F4 Technical Visa (FO.CAO.00026-001) 6.3 Surveillance Plan (TE.CAO.00029-001) 6.4 Part 145 Appendix IV compliance check list (FO.CAO.00028-001)6.5 ICAO Annex I compliance check list (FO.CAO.00030-001) 6.6 Emergency Part 145 level 1 finding notification form

(FO.CAO.00027-001)

Additional instructions for use of these forms can be found within the document UG.CAO.00005-000 “Foreign Part 145 approvals User guide for NAA / EASA”







7.User Guides







7.1 UG.CAO.00005-000 “Foreign Part 145 approvals User guide for NAA / EASA”

This user guide gives instruction for:o Instruction for use of the EASA Foreign Form 6o Instruction for use of the MOE/F4 Technical Visao Instruction for use of the Appendix IV compliance check listo Instruction for C/S and support staff assessment o Instruction for Component Certifying Staffo Instruction for desktop audito Instruction for Foreign Part 145 Line Stationo Instruction for allocation of technical working hours

7.2 UG.CAO.00024-000 “Foreign Part 145 approvals - User guide for Maintenance Organisation Exposition”

7.3 UG.CAO.00006-000 “Foreign Part 145 approvals - User guide for Applicants







RECORDS

Appendix A : Operational Documents

Record Step / Related to

Appendix B : External Documents

Record Step / Related to

Foreign Part 145 approvals - EASA€¦ · Web viewThe Agency is the competent authority for...

Documents

Transcript of Foreign Part 145 approvals - EASA€¦ · Web viewThe Agency is the competent authority for...