Knowledge databank

Yes, you do not need to have the full capability. The Disassembly Best Management Practice (BMP) for Management of Used Aircraft Parts and Assemblies (rev 04) allows both Contracted Disassembly and Contracted Recycling.

Definition of Contracted Disassembly:
Disassembly of an Asset, (i.e. Aircraft, Aerospace materials, and/or components) in which the contracted third party facility ensures that there is a procedure in place for evaluating and selecting the disassembly facility so as to assure the contracted firm can adequately meet the Facility’s AFRA BMP Requirements.

NOTE: Facilities desiring to be accredited for Contracted Disassembly must have the auditable means to assure the Contracted Facilities are able to meet all the applicable requirements of the AFRA BMP.

Definition of Contracted Recycling:
Recycling of an Asset (i.e. Aircraft, Aerospace materials, and/or components) in which the Disassembly facility ensures that there is a procedure in place for evaluating and selecting a contracted recycling firm so as to assure the contracted firm can adequately meet the AFRA Recycling BMP Requirements.

NOTE: Facilities desiring to be accredited for Contracted Recycling must have the auditable means to assure the Contracted Recycling Firms are able to meet all the applicable requirements of the Recycling BMP.

The Disassembly Practice Guide and Minimum Standards defines the details on how to contract Disassembly and/or Recycling.

Submit the AFRA Audit Application to begin the process.

Schedule Your Audit

Once your application has been accepted, AFRA staff will work with your company and the auditor to set up your audit date. The date will vary depending on availability.

Your company is responsible for the auditor’s travel fees associated with your audit. However, when audits are scheduled in tandem with other nearby companies, you may be able to share travel fees with other companies being audited.

Complete the Checklist

All companies will be required to complete the Audit Checklist in order to have the application accepted by AFRA.

Current Accreditation Fee Structure

• For any one (1) accreditation subset, the Accreditation fee will remain the same as the previous Single Accreditation fee of $7,000 (plus travel auditor expenses).
• For any combination of two (2) accreditation subsets, the Accreditation fee will remain the same as the previous Dual Accreditation fee of $9,400 (plus travel auditor expenses).
  • The one exception to the above is that for any company that is Accredited for both Disassembly and Demolition, the Accreditation fee will remain $7,000 because of the unique relationship between the aforementioned.
• For any combination of three (3) Accreditation subsets, the third subset will be assessed at a flat-cost of $975 added to $9,400 (with the exception to Disassembly & Demolition).
• When remitting payment, you will be invoiced for one-third of your Accreditation fee annually.

AFRA offers five accreditation types to meet your business expertise: Demolition, Disassembly, Contracted Disassembly, Recycling, and Contracted Recycling.

Submit the AFRA Audit Application to begin the process.

Yes, both are technically equivalent. The AS-9100 is the American standard while the EN-9100 is the European standard.

By managing, controlling, and auditing your own processes, as well as having an outside certification body verifying that your QMS meet the requirements, your customers can know that everything is well in hand.

As the internationally recognized standard for aerospace Quality Management Systems, AS/EN-9100 is based on seven quality management principles that are recognized as necessary to make a Quality Management System work. Your customers will be content to know that your QMS is also based on these principles. To find out more about these principles, which are also applicable to ISO 9001, see this article on The seven quality management principles behind ISO 9001 requirements.

One of the biggest benefits of AS/EN-9100 certification is that every certified company must be included on the Online Aerospace Supplier Information System (OAIS) maintained by the IAQG. This is a searchable database that is available for any company in the aerospace industry that is looking at supplier selection and surveillance, and includes not only information about each company, but also contact information for purchasing.

AS/EN-9100 is the international Quality Management System standard for the Aviation, Space and Defense (AS&D) industry, created by the IAQG, and AS9100 Rev D (2016) and EN-9100:2018 are the most recent version.

The standard provides suppliers with requirements for creating and maintaining a comprehensive quality system for providing safe and reliable products to the Aviation Space and Defense industry, as well as civil & military aviation requirements.

The AS/EN-9100 standard specifies the QMS requirements to be documented and implemented by organisations designing, developing and manufacturing aerospace products.

EN-9100 certified means and organisation has met the requirements of EN-9100:2018.

Yes, both are technically equivalent. The AS-9110 is the American standard while the EN-9110 is the European standard.

• Comply with contractual requirements from the growing number of Customers requiring 9110 certification (increased ability to bid for new contracts).
• Higher quality services at reduced cost.
• Shared supplier approval and audit results database (certificated organizations are listed in OASIS).
• Increased recognition by Regulatory Authorities and stakeholders.
• For non-certificated organizations to demonstrate QMS compliance against a recognized MRO Quality Management System leading to potential NAA certification.

It is mainly applicable to MRO but also to other organisations like Airlines/CAMO and for both civil and military sectors.

Yes, both are technically equivalent. The AS-9120 is the American standard while the EN-9120 is the European standard.

• Well defined and documented procedures improve the consistency of output
• Quality is constantly measured
• Procedures ensure corrective action is taken whenever defects occur
• Defect rates decrease
• Defects are caught earlier and are corrected at a lower cost
• Defining procedures identifies current practices that are obsolete or inefficient
• Documented procedures are easier for new employees to follow
• Organizations retain or increase market share, increasing sales or revenues

It is for Stockist and Distributors – emphasis is on parts identification, traceability and documentation to reduce the risk of the bogus or counterfeit parts being used.

AS/EN9120 is the Quality Management Standard based on ISO 9001 but specifically designed for the Aerospace & Defence Industries.

ASA has published the steps to become accredited here.

This is a standard that has been developed by the ASA Quality Assurance Committee. Its purpose is to provide aviation suppliers with a quality system which satisfies the requirements outlined in FAA Advisory Circular 00-56: Voluntary Industry Distributor Accreditation Program.

You can find them on the Aviation Supplier Association (ASA) website: https://www.aviationsuppliers.org/ASA-100-Documents

The CAAC describes on her website the following steps for initial application, being:

Step 1: Submit the application form for issue of maintenance organisation certificate (F145-1).

CAAC has an online IT system, all required documents should be uploaded into Portal: http://fsop.caac.gov.cn/ In order to get an account you need to contact CAAC to get Portal Account.

Contact information:

Ms ZHAO Yayan: zhaoyy@mail.castc.org.cn (for companies from Germany, UK, Canada and TAI Wan).

Mr GU Jiazheng: gujz@mail.castc.org.cn (for companies from USA, EXCEPT those from state of TX, CA and FL).

Mr ZHANG Lei: zhangl@mail.castc.org.cn (for companies from France and Asia, EXCEPT those from TAI WAN).

Ms ZHAO Yang: zhaoyang@mail.castc.org.cn (for the rest companies).

Step 2: Write the Maintenance Management Manual (Refer to AC-145-5 for instructions on development of the Manual and submit this to the CAAC portal as well.

Step 3: Upload the Maintenance capability list to the CAAC portal (only for applicant applying for aircraft component or line maintenance function of Airframe ratings).

Step 4: Submit the Compliance Statement and other related documents. See AC-145-1-en-Application Guide for Domestic Maintenance Organization Certificate for details on the statement and related documents

Step 5: Submit the Letter of Intent from the customer. The following letter of intent acceptable to CAAC is necessary for initial application and adding new functions/ratings:

• i.A letter of intent from Chinese customer.

• ii.A letter of intent from non-Chinese customer, the supplemental proof document shall be included or submitted separately to show the business intent may be traced back to the demands of Chinese customer eventually.

Step 6: Upload A copy of latest valid Maintenance Organization Certificate issued by the national/regional civil aviation authority (e.g. EASA Form 3) on the CAAC Portal.

Step 7: Formal Meeting with CAAC in Beijing & Notification:
New applicant should meet with related with PMI for interview, and CAAC will notify applicant with formal notification.

Step 8: Documents review and Onsite Audit.

Step 9: Certification.

Important Remark: Management of the Maintenance Organisation that applies for the CAAC MOC needs to conduct formal CAAC CCAR Part-145 training in Beijing.

The applicant applying for the CAAC MOC shall be:

(1)A legal person registered under the relevant national law or an organisation so authorize in writing by such legal person, which shall be familiar with the requirements of this regulation and competent to perform the maintenance work on the maintenance rating(s)/item(s) being applied;

(2)The maintenance rating(s)/item(s) that a foreign or regional applicant applies for CAAC approval shall be for China registered civil aircraft or components thereof, and also be approved by the competent Civil Aviation Authority which has jurisdiction over the maintenance organization concerned.

The current revision of the CCAR Part 145 is revision R3. These can be found on the website of the CAAC

Those can be found on the CAAC website. The relevant regulations related to CAAC Maintenance Organisation Certification are:

• CCAR-145-R3-en-Civil Aircraft Maintenance Organization Certification Regulations
• AC-145-1-en-Application Guide for Domestic Maintenance Organization Certificate
• AC-145-2R1-en-Application Guide for Foreign/Regional Maintenance Organization Certificate
• AC-145-4-en-Maintenance Records and Reports
• AC-145-5-en-Guide for Compiling of Maintenance Organization Manual
• AC-145-06R1-en-Aircraft Line Maintenance
• AC-145-7-en-Maintenance of Aircraft Components
• AC-145-8-en-Technical Documents for Aircraft and Aircraft Components Maintenance
• AC-145-9-en-Adoption of National and Industrial Standard
• AC-145-10-en-Self-manufactured Tools and Equipment by Maintenance Organization
• AC-145-11-en-CAAC/CAD (Hong Kong)/AACM (Macao) Joint Certification
• AC-145-12-en-Limited Ratings of Airframe Maintenance
• AC-145-13R1-en-Guidelines for AC-145-13R1 MRO Training Program Manual Compilation
• CCAR-147-en-The Regulations on Certification of Civil Aircraft Maintenance Personnel Training Organizations
• AC-147-01-en-APPLICATION GUIDE FOR CIVIL AVIATION AIRCRAFT MAINTENANCE TRAINING ORGANIZATION
• AC-147-04R1-en-The Training Program on Repair Items of Civil Aviation Aircraft Types and Components
• AC-147-05-en-EDIT GUIDE FOR CIVIL AVIATION AIRCRAFT MAINTENANCE TRAINING ORGANIZATION MANAGEMENT MANUAL
• AC-147-06-en-FILING GUIDE FOR CIVIL AVIATION AIRCRAFT MAINTENANCE TRAINING ORGANIZATION ANNUAL REPORT
• CCAR-135-en-RULES ON OPERATION CERTIFICATION OF SMALL AIRCRAFT COMMERCIAL TRANSPORT OPERATORS
• CCAR-66R1-Management Rule of Civil Aircraft Maintenance Personnel License

Yes, but it is limited.

The approved data necessary to fabricate the part are those approved either by the Agency, the TC holder, Part-21 design organisation approval holder, or STC holder.

EASA Part-M.A.603 (Subpart F) (c) and EASA Part-145.A.40 (b) III indicates that an approved maintenance organisation may fabricate, in conformity with maintenance data, a restricted range of parts for the use in the course of undergoing work within its own facilities, as identified in the maintenance organisation manual.

These own fabricated parts may not sold and can only used for the purpose of the maintenance organisation.

Example of the restricted range of parts are:

(a) fabrication of bushes, sleeves and shims,
(b) fabrication of secondary structural elements and skin panels,
(c) fabrication of control cables,
(d) fabrication of flexible and rigid pipes,
(e) fabrication of electrical cable looms and assemblies,
(f) formed or machined sheet metal panels for repairs.

Basically yes, but there are exemptions, for example the smaller “Part-M subpart F Maintenance Organisations” or inside the airforce. But in general the officials of the NAA (National Aviation Authorities) of an EU member state demand that the experience is acquired in a (aircraft) Part-145 approved maintenance organisation. You must show your experience in a logbook, the requirements for these logbooks can be Member State specific.

There are no direct instructions in the EASA regulations on how to correct a CRS, like there are for correcting an EASA Form-1. That is because a CRS is not a predefined EASA Form and has therefore no pre-defined lay-out, like an EASA Form-1 has.

The only things required for a CRS (lay-out and correction) is detailed in EASA Part-M.

M.A.801 (e) A CRS shall contain at least:

1. basic lay-out of the maintenance carried out;
2. the date on which the maintenance was completed;
3. the identity of the organisation or person issuing the CRS, including, alternatively:
   (i) the approval reference of the maintenance organisation and the certifying staff issuing the CRS;
   (ii) in case referred to in point (b)(2), the identity and, where applicable, the licence number of the certifying staff issuing the CRS;
4. the limitations to airworthiness or operations, if any.

EASA Part-M details in M.A.305 (a) and (g) that:

(a) At the completion of any maintenance, aircraft certificate of release to service (‘CRS’) required by point M.A.801 or point 145.A.50, as applicable, shall be entered in the aircraft continuing airworthiness record system, as soon as practicable and no later than 30 days after the completion of any maintenance.

(g) All entries made in the aircraft continuing airworthiness record system shall be clear and accurate. When it is necessary to correct an entry, the correction shall be made in a manner that clearly shows the original entry.

Besides the changes in the management team (Compliance Monitoring Manager & Safety Manager), EASA Part-145 Approved Maintenance Organizations also need to implement the elements of a suitable SMS.

The mandated SMS system must contain the following elements:

• finding out what is wrong (hazard identification);
• proposing and implementing a fix or fixes (remedial action);
• making sure that the proposed fix or fixes work as intended (continuous monitoring); and
• constantly improving the management system to ensure effectiveness and efficiency of the delivery of services (continuous improvement of the SMS).

Procedures and instructions need to be developed, and a separate Safety Management Manual is recommended. Especially if you are a large and complex organisation.

Depending on the size of the organization, a suitable SMS software system that support the reporting needs and data collection and retention of the essential SMS elements is recommended.

This SMS software should be capable of providing reports and data related to the continuous monitoring and continuous improvements of the SMS.

And finally, provisions need to be made in the training program for the training of required staff in Safety Management and Compliance Monitoring functions. Safety Management training is combined with Human Factors training and the course syllabus is detailed in GM1 145.A.30(e). Safety Management needs to be promoted, and a solid SMS training program is one of the means of promoting Safety within your organisation.

Yes, your AML (Aircraft Maintenance Licence) remains valid for 5 years. Normally the AML is referred to as being a Part-66 licence. From the Part-145 company you will get a Company Authorisation, which allows you to work (and release aircraft) for that specific company.

Yes, but under specific circumstances as detailed below.

There can be multiple items on a EASA form-1, but it must be related to a work order. (Both examples below come from a 21G).

For EASA Form-1’s issued by Part-145 organisations it is allowed as well as long as it is also related to the same work order. See example below for details of different part numbers on an EASA Form-1 related to the same work order.

It is not allowed to mix EASA Part-21G produced parts with EASA Part-145 maintained parts on one EASA Form-1.

Yes,

It is possible if the Part-145 company has a procedure for this, described in the MOE. Only serviceable components can be re-installed. So components which are suspected to be faulty, should not be allowed.

M.A.502 (b) states:

No. There are no direct requirements in the EASA Part-M / EASA Part-145 regulations. We advise organisations to stamp or watermark non-original EASA Form 1’s with “Duplicate” or “Copy” to distinguish them from the original document.

No, there are no formal requirements in the EASA Part-21 or -145 regulations requiring physical separation of Part-21 stock items from Part-145 stock items.

What is important, is that the Part-145 may only use parts listed in the IPC/IPL. Part-21 can use items for proto types or from drawings. These parts should not be issued in a Part-145 environment.

The parts or items in the shared stockrooms must of course be provided with batch numbers, locations, etc. The entire trace and end-use (Part-21 and/or Part-145) must be recorded in the ERP.

What is a complex motor powered aircraft?

(i) an aeroplane:

— with a maximum certificated take-off mass exceeding 5 700 kg, or

— certificated for a maximum passenger seating configuration of more than nineteen, or

— certificated for operation with a minimum crew of at least two pilots, or

— equipped with (a) turbojet engine(s) or more than one turboprop engine, or

(ii) a helicopter certificated:

— for a maximum take-off mass exceeding 3 175 kg, or

— for a maximum passenger seating configuration of more than nine, or

— for operation with a minimum crew of at least two pilots, or

(iii) a tilt rotor aircraft;

When you have succesfully passed all the EASA Part-66 module examinations you must first gain a couple of years of Experience. Then you can apply (at the NAA of an EU member state) for an EASA Part-66 Aircraft Maintenance Licence. Then you need to follow a specific Aircraft Type (or Task) training, for example “Boeing 737-600/700/800/900 (CFM56)”. To add the first aircraft type to a Part-66 (Cat B1 or B2 rating) you must succesfully complete the: Theoretical element + Practical element + On-The-Job Training. 

Then the approved maintenance company, being a Part-145 (Or Part-M supart F) can grant you the “Release Priviledge”. With this priviledge you are allowed to release aircraft for service on behalf of the Approved Maintenance Company.

Introducing the new ‘MANAGEMENT SYSTEM’. 145.A.65 ‘Safety and quality policy, maintenance procedures and quality system’, will be changed into 145.A.65 ‘Maintenance System’. 145.A.65 ‘Maintenance System’ reproduces all elements of the management system requirements including the organisation requirements and related AMC. These changes are supported by a series of Guidance Material specific to the context of maintenance organisations, with particular focus on Human Factors and Safety Risk Management/Fatigue Risk Management.

The new management system provisions are introduced to ensure maximum flexibility by defining core requirements of the management system at Implementing Rule (IR) level, and including the detailed means to achieve these goals at AMC level. They also allow considering those elements that are already in place today in any Part-145 Approved Maintenance Organisation, in terms of quality system related provisions that deliver the ‘compliance monitoring function’ of the new management system requirements.

Most of the provisions related to ‘quality system’ in the current Part-145 deals with the monitoring of compliance and related reporting and corrective action processes. As there are multiple types of quality systems defined in different international or national standards, with different meanings and scopes, it is more appropriate to refer to compliance monitoring function when it comes to Part-145. This does not mean that organisations will be required to change designations of their quality system personnel. It is left up to each organisation to decide how to refer to this function. Conversely, at the level of the requirements, no reference to ‘quality system’ will remain.

No longer ‘Quality System’. The former term ‘quality system’ is not used any longer. It has been replaced by ‘management system, in order to define a consistent set of management system requirements that would be compatible with a wide range of management system standards. This new management system focusses primarily on the monitoring of compliance, a proper reporting to management, and the need to take effective corrective actions.

‘Quality Manager’ will be replaced by ‘Compliance Monitoring Manager’ and an additional manager function will be introduced in EASA Part 145: the ‘Safety Manager’. The Safety Manager is responsible for the development, administration, and maintenance of effective safety management processes as part of the management system in accordance with 145.A.65.

For non-complex organisations, the Compliance Monitoring Manager and Safety Manager can be one person, although this is not recommended for the larger, complex organisations.

‘Quality audit personnel’ will be replaced by ‘Compliance Monitoring and safety management personnel’. The organization’s compliance monitoring personnel performs the same work as it was described for the previous quality audit personnel and they may request the safety management personnel to perform a safety risk assessment.
All these changes and additions will mainly impact MOE chapter 1.1 up to 1.5 and chapter 3.

“MOE chapter 3 Management System Procedures” does no longer include “quality” in the title and the following altered and new paragraphs need to be developed and implemented in MOE chapter 3:

There is no clear answer to this question, it depends on the purpose (What is your intent?). Please consult: https://amc66.com/index.php/en/logbooks  for a detailed explanation.

EASA wants to further improve the level of safety with respect to EASA Part-145 Approved Maintenance Organizations. The principles of safety management as indicated in the ICAO Annex 19 SARP’s will be fostered and the procedures for oversight and enforcement will be streamlined.

The safety risks introduced by the aviation industry must result in an Acceptable Level of Safety (or ALoS). Acceptable level means as long as safety risks and operational errors are kept under a reasonable degree of control, a system as open and dynamic as commercial civil aviation is considered to be safe. In other words, safety risks and operational errors that are controlled to a reasonable degree are acceptable in an inherently safe system.

The EASA system establishes at legislative level the safety objectives to be met by means of essential requirements. These requirements have been designed to mitigate any probable risk linked to civil aviation activities within the scope of the EASA system. These mitigating means will be further detailed in appropriate Part-145 Implementing Rules (IR), Acceptable Means of Compliance (AMC) and Guidance Material (GM).

So why do we need to implement SMS, besides complying with the EASA regulations?

Because, besides achieving Improved Safety, it will also result in Continuous Improvement of operational processes and Repetitive Common Cause Accidents will essentially be eliminated.

This can only be achieved when EASA Part-145 Approved Maintenance Organizations move from a reactive to a proactive and predictive approach towards safety risks.

Implementation of SMS also has financial benefits. Besides cost reduction and cost avoidance, it will also result in a reduction of the direct and indirect costs of accidents, incident investigation and operational disruptions.

And finally, implementing an effective SMS, will provide EASA Part-145 Approved Maintenance Organizations with a competitive benefit. That is as mentioned before because of the financial benefits, but also because a well matured SMS will result in establishing a marketable safety record.

Yes, but under specific circumstances as detailed below.

There can be multiple items on a EASA form-1, but it must be related to a work order. (Both examples below come from a 21G).

For EASA Form-1’s issued by Part-145 organisations it is allowed as well as long as it is also related to the same work order. See example below for details of different part numbers on an EASA Form-1 related to the same work order.

It is not allowed to mix EASA Part-21G produced parts with EASA Part-145 maintained parts on one EASA Form-1.

No, there are no formal requirements in the EASA Part-21 or -145 regulations requiring physical separation of Part-21 stock items from Part-145 stock items.

What is important, is that the Part-145 may only use parts listed in the IPC/IPL. Part-21 can use items for proto types or from drawings. These parts should not be issued in a Part-145 environment.

The parts or items in the shared stockrooms must of course be provided with batch numbers, locations, etc. The entire trace and end-use (Part-21 and/or Part-145) must be recorded in the ERP.

Because we need input from you. Send us your question via the contact form on our website and we will work out and display an answer on this page.

An EASA approved Part-147 Maintenance Training Organisation means that the organisation (books, exams, teachers, facility, etc) are accepted by the local Member State National Aviation Authroities. The organisation must be in compliance with the EASA Part-147 regulations. An approved Part-147 organisation is allowed to perform Part-66 module examinations at other locations. 

Your AML (EASA Part-66) is valid for 5 years. You must renew your AML before it expires.

Basically yes, but there are exemptions, for example the smaller “Part-M subpart F Maintenance Organisations” or inside the airforce. But in general the officials of the NAA (National Aviation Authorities) of an EU member state demand that the experience is acquired in a (aircraft) Part-145 approved maintenance organisation. You must show your experience in a logbook, the requirements for these logbooks can be Member State specific.

In the EASA Part-66 regulation is stated that only after 90 days you can retake a specific Part-66 Module Examination. Only after a dedicated re-training by a Part-147 Maintenance Training Organisation you are entitled to retake an examintion after 30 days. The maximum number of retakes is 3 consecutives attempts, after the third attempt you must wait for at least 1 year. This is regardless if these examinations were taken at other approved Part-147 Maintenance Training Organisations.

Yes, EASA Part-66 (Regulation (EU) No 1321/2014) states:

For the purpose of time limits contained in points 66.A.25, 66.A.30 and Appendix III of Annex III (Part-66) related to basic knowledge examinations, basic experience, theoretical type training and examinations, practical training and assessment, type examinations and on the job training completed before Regulation (EU) No 1149/2011 applied, the origin of time shall be the date by which Regulation (EU) No 1149/2011 applied.
Regulation (EU) No 1149/2011 applies from 01-08-2012.

This means that your Certificates of Recognition from e.g. 2007, 2008, 2009, etc remain valid until 31-07-2022 (10 years from 01-08-2012).

Yes, your AML (Aircraft Maintenance Licence) remains valid for 5 years. Normally the AML is referred to as being a Part-66 licence. From the Part-145 company you will get a Company Authorisation, which allows you to work (and release aircraft) for that specific company.

A good preparation is important. You need to be present at the examination location, at least 15 minutes prior to the start of the examination. You must be able to officially identify yourselves before the examination starts. If the Examinor (the invigilator) can not establish your identity, you are not allowed to participate inside the examination. Also should bring a ballpoint (colors black or blue). You are not allowed to take your phone, smart watches, papers, etc to the examination.

AML means Aircraft Maintenance Licence and is normally called a Part-66. This official document is issued by the aviation authorities of an EU member state. On this document is stated for which category the holder of the AML is approved. After the succesfull completion of an aircraf type training course (Theory + Practical + OJT) the aircraft types are added (only applicable to Part-66 categories B1, B2 and C) on the Part-66 AML.

There is a significant difference between passing all Part-66 Module Examinations or passing a Part-66 Basic Training. The difference is the expierence requirement (number of years) before you can apply for a Part-66 AML. In general it can be stated that the experience duration requirement is significant shorter after following a Part-66 Basic Training course. The experience requirements depend on the Category you apply for.

When you have succesfully passed all the EASA Part-66 module examinations you must first gain a couple of years of Experience. Then you can apply (at the NAA of an EU member state) for an EASA Part-66 Aircraft Maintenance Licence. Then you need to follow a specific Aircraft Type (or Task) training, for example “Boeing 737-600/700/800/900 (CFM56)”. To add the first aircraft type to a Part-66 (Cat B1 or B2 rating) you must succesfully complete the: Theoretical element + Practical element + On-The-Job Training. 

Then the approved maintenance company, being a Part-145 (Or Part-M supart F) can grant you the “Release Priviledge”. With this priviledge you are allowed to release aircraft for service on behalf of the Approved Maintenance Company.

Where can I find more information relating to EASA Part-66 ?

For more information you can go to the EASA website or to the website of the Civil Aviation Authority in your country. 

There is no clear answer to this question, it depends on the purpose (What is your intent?). Please consult: https://amc66.com/index.php/en/logbooks  for a detailed explanation.

No.

CAMO plus is a “commercial” term and not an official EASA term. CAMO plus is considered to be a CAMO with Airworthiness Review privileges.

What is a complex motor powered aircraft?

(i) an aeroplane:

— with a maximum certificated take-off mass exceeding 5 700 kg, or

— certificated for a maximum passenger seating configuration of more than nineteen, or

— certificated for operation with a minimum crew of at least two pilots, or

— equipped with (a) turbojet engine(s) or more than one turboprop engine, or

(ii) a helicopter certificated:

— for a maximum take-off mass exceeding 3 175 kg, or

— for a maximum passenger seating configuration of more than nine, or

— for operation with a minimum crew of at least two pilots, or

(iii) a tilt rotor aircraft;

Part CAMO is applicable for Complex motor powered aircraft /owners and operators.

Part-CAMO is mandatory if you have an AOC.

Part-CAMO must be in place ultimately on 24-Sep-2021

What is a complex motor powered aircraft?

(i) an aeroplane:

— with a maximum certificated take-off mass exceeding 5 700 kg, or

— certificated for a maximum passenger seating configuration of more than nineteen, or

— certificated for operation with a minimum crew of at least two pilots, or

— equipped with (a) turbojet engine(s) or more than one turboprop engine, or

(ii) a helicopter certificated:

— for a maximum take-off mass exceeding 3 175 kg, or

— for a maximum passenger seating configuration of more than nine, or

— for operation with a minimum crew of at least two pilots, or

(iii) a tilt rotor aircraft;

Part-CAO is combined CAMO with Maintenance.

Part-CAO is applicable for non-AOC aircraft and for other than complex motor-powered aircraft.

Yes, but it is limited.

The approved data necessary to fabricate the part are those approved either by the Agency, the TC holder, Part-21 design organisation approval holder, or STC holder.

EASA Part-M.A.603 (Subpart F) (c) and EASA Part-145.A.40 (b) III indicates that an approved maintenance organisation may fabricate, in conformity with maintenance data, a restricted range of parts for the use in the course of undergoing work within its own facilities, as identified in the maintenance organisation manual.

These own fabricated parts may not sold and can only used for the purpose of the maintenance organisation.

Example of the restricted range of parts are:

(a) fabrication of bushes, sleeves and shims,
(b) fabrication of secondary structural elements and skin panels,
(c) fabrication of control cables,
(d) fabrication of flexible and rigid pipes,
(e) fabrication of electrical cable looms and assemblies,
(f) formed or machined sheet metal panels for repairs.

There are no direct instructions in the EASA regulations on how to correct a CRS, like there are for correcting an EASA Form-1. That is because a CRS is not a predefined EASA Form and has therefore no pre-defined lay-out, like an EASA Form-1 has.

The only things required for a CRS (lay-out and correction) is detailed in EASA Part-M.

M.A.801 (e) A CRS shall contain at least:

1. basic lay-out of the maintenance carried out;
2. the date on which the maintenance was completed;
3. the identity of the organisation or person issuing the CRS, including, alternatively:
   (i) the approval reference of the maintenance organisation and the certifying staff issuing the CRS;
   (ii) in case referred to in point (b)(2), the identity and, where applicable, the licence number of the certifying staff issuing the CRS;
4. the limitations to airworthiness or operations, if any.

EASA Part-M details in M.A.305 (a) and (g) that:

(a) At the completion of any maintenance, aircraft certificate of release to service (‘CRS’) required by point M.A.801 or point 145.A.50, as applicable, shall be entered in the aircraft continuing airworthiness record system, as soon as practicable and no later than 30 days after the completion of any maintenance.

(g) All entries made in the aircraft continuing airworthiness record system shall be clear and accurate. When it is necessary to correct an entry, the correction shall be made in a manner that clearly shows the original entry.

No. There are no direct requirements in the EASA Part-M / EASA Part-145 regulations. We advise organisations to stamp or watermark non-original EASA Form 1’s with “Duplicate” or “Copy” to distinguish them from the original document.

No.

CAMO plus is a “commercial” term and not an official EASA term. CAMO plus is considered to be a CAMO with Airworthiness Review privileges.

What is a complex motor powered aircraft?

(i) an aeroplane:

— with a maximum certificated take-off mass exceeding 5 700 kg, or

— certificated for a maximum passenger seating configuration of more than nineteen, or

— certificated for operation with a minimum crew of at least two pilots, or

— equipped with (a) turbojet engine(s) or more than one turboprop engine, or

(ii) a helicopter certificated:

— for a maximum take-off mass exceeding 3 175 kg, or

— for a maximum passenger seating configuration of more than nine, or

— for operation with a minimum crew of at least two pilots, or

(iii) a tilt rotor aircraft;

What is a complex motor powered aircraft?

(i) an aeroplane:

— with a maximum certificated take-off mass exceeding 5 700 kg, or

— certificated for a maximum passenger seating configuration of more than nineteen, or

— certificated for operation with a minimum crew of at least two pilots, or

— equipped with (a) turbojet engine(s) or more than one turboprop engine, or

(ii) a helicopter certificated:

— for a maximum take-off mass exceeding 3 175 kg, or

— for a maximum passenger seating configuration of more than nine, or

— for operation with a minimum crew of at least two pilots, or

(iii) a tilt rotor aircraft;

Part-ML (M Light) is applicable for: NON-AOC aircraft (not registered and thus do not operate under an AOC).

Part-ML is applicable for: – other than complex motor-powered aircraft:

• Aeroplanes of 2730 kg or less
• Rotorcraft of 1200 kg or less, certified for max. up to 4 occupants
• Other ELA-2 aircraft.

No.

CAMO plus is a “commercial” term and not an official EASA term. CAMO plus is considered to be a CAMO with Airworthiness Review privileges.

Yes and no. They are very similar. The main differences:

• The Basic Knowledge modules are similar, but for example in Module 7A (Maintenance Practices) and additional sub-chapter is added relating “Armament Safety”.
• The EMAR-66 has additional “military specific system” modules, being:
  • Module 50: Principles of armament
  • Module 51: Weapon systems
  • Module 52: Operational Attack Systems
  • Module 53: Surveillance and electronic warfare
  • Module 54: Crew Safety
  • Module 55: Military Communication Systems

No, the EMAR only has the Categories: A, B1, B2 and C. The A and B1 Categories also have the sub-categories. The EMAR did not follow EASA with the following Categories: B3, B2L and L

Yes, the EMAR requirements (and Guidance Material) specifically allow such conversions. Such conversions will often result in Basic Limitations on the MAML of the affected persons. To avoid and mitigate the risks / consequences, please contact the partners from ACSG (info@acsg.aero).

Normally Yes, but you must have sufficient experience in maintaining military aircraft and you would need to additionally pass the “Military Specific System” modules. If you did not pass these MSS modules, some restrictions could apply.

No, the EMAR 66 is only applicable for aircraft maintenance staff.

No, the European Military Airworthiness Requirements (EMAR) are adopted requirements in each of the participating national airforces. Products manufactured or maintained will (normally) be commonly accepted in other nations, but are not “mutually accepted”. The system is more comparable to the Joint Aviation Requirements, which are requirements and must be adopted in the national regulations. The European Defence Agency published the EMAR’s and the Guidance Material.

Very similar to an EASA AML:

• Knowledge; (1) proven with exams/credits by Authority or Part-147, (2) based upon an EASA Part-66 AML or (3) conversion of existing national military licence system.
• Experience (must including military aircraft)
• Proper paperwork (form 19), compliant with procedures.

Each National Military Airworthiness Authority (NMAA) must issue there own national version of the EMAR-66. In the Netherlands this are the MLE-66 and for example in Belgium this are the BMAR-66.

You must comply with the forms and procedures of the national variances, so you must check with your National Military Airworthiness Authority (NMAA) the proper national procedure.

European Defence Ministers tasked the EDA (European Defence Agency) to prepare for the creation of a formal EU-wide Forum for Military Airworthiness Authorities and to propose a roadmap for European military airworthiness harmonisation and how this could be implemented. The MAWA Forum is chaired and supported by the EDA, but it does not have the authority to impose airworthiness regulations on individual nations, who retain their sovereignty for military airworthiness. This all means that the EMAR’s are published on the website of the EDA, but depends on the participating member states to adopt them.

The National Military Airworthiness Authority (NMAA), but they are allowed to delegate this to another entity.

Because we need input from you. Send us your question via the contact form on our website and we will work out and display an answer on this page.

Because we need input from you. Send us your question via the contact form on our website and we will work out and display an answer on this page.

Because we need input from you. Send us your question via the contact form on our website and we will work out and display an answer on this page.

Besides the changes in the management team (Compliance Monitoring Manager & Safety Manager), EASA Part-145 Approved Maintenance Organizations also need to implement the elements of a suitable SMS.

The mandated SMS system must contain the following elements:

• finding out what is wrong (hazard identification);
• proposing and implementing a fix or fixes (remedial action);
• making sure that the proposed fix or fixes work as intended (continuous monitoring); and
• constantly improving the management system to ensure effectiveness and efficiency of the delivery of services (continuous improvement of the SMS).

Procedures and instructions need to be developed, and a separate Safety Management Manual is recommended. Especially if you are a large and complex organisation.

Depending on the size of the organization, a suitable SMS software system that support the reporting needs and data collection and retention of the essential SMS elements is recommended.

This SMS software should be capable of providing reports and data related to the continuous monitoring and continuous improvements of the SMS.

And finally, provisions need to be made in the training program for the training of required staff in Safety Management and Compliance Monitoring functions. Safety Management training is combined with Human Factors training and the course syllabus is detailed in GM1 145.A.30(e). Safety Management needs to be promoted, and a solid SMS training program is one of the means of promoting Safety within your organisation.

SMS is a system that identify hazards and take action to reduce the applicable risks to and acceptable level.

Within SMS:

• Hazards are actively identified,
• Hazards can be a Risk, so it includes Risk Management (process)
• It looks into, how can we lower the Risk (Mitigation actions)
• A change (corona, rules, mode of operations) could introduce new hazards and thus new risks. (Management of Change)

SMS is everyone’s responsibility, this means everyone needs to understand the importance of this system and their respective responsibility. Think of attitude.

SMS must be driven by Management.

Introducing the new ‘MANAGEMENT SYSTEM’. 145.A.65 ‘Safety and quality policy, maintenance procedures and quality system’, will be changed into 145.A.65 ‘Maintenance System’. 145.A.65 ‘Maintenance System’ reproduces all elements of the management system requirements including the organisation requirements and related AMC. These changes are supported by a series of Guidance Material specific to the context of maintenance organisations, with particular focus on Human Factors and Safety Risk Management/Fatigue Risk Management.

The new management system provisions are introduced to ensure maximum flexibility by defining core requirements of the management system at Implementing Rule (IR) level, and including the detailed means to achieve these goals at AMC level. They also allow considering those elements that are already in place today in any Part-145 Approved Maintenance Organisation, in terms of quality system related provisions that deliver the ‘compliance monitoring function’ of the new management system requirements.

Most of the provisions related to ‘quality system’ in the current Part-145 deals with the monitoring of compliance and related reporting and corrective action processes. As there are multiple types of quality systems defined in different international or national standards, with different meanings and scopes, it is more appropriate to refer to compliance monitoring function when it comes to Part-145. This does not mean that organisations will be required to change designations of their quality system personnel. It is left up to each organisation to decide how to refer to this function. Conversely, at the level of the requirements, no reference to ‘quality system’ will remain.

No longer ‘Quality System’. The former term ‘quality system’ is not used any longer. It has been replaced by ‘management system, in order to define a consistent set of management system requirements that would be compatible with a wide range of management system standards. This new management system focusses primarily on the monitoring of compliance, a proper reporting to management, and the need to take effective corrective actions.

‘Quality Manager’ will be replaced by ‘Compliance Monitoring Manager’ and an additional manager function will be introduced in EASA Part 145: the ‘Safety Manager’. The Safety Manager is responsible for the development, administration, and maintenance of effective safety management processes as part of the management system in accordance with 145.A.65.

For non-complex organisations, the Compliance Monitoring Manager and Safety Manager can be one person, although this is not recommended for the larger, complex organisations.

‘Quality audit personnel’ will be replaced by ‘Compliance Monitoring and safety management personnel’. The organization’s compliance monitoring personnel performs the same work as it was described for the previous quality audit personnel and they may request the safety management personnel to perform a safety risk assessment.
All these changes and additions will mainly impact MOE chapter 1.1 up to 1.5 and chapter 3.

“MOE chapter 3 Management System Procedures” does no longer include “quality” in the title and the following altered and new paragraphs need to be developed and implemented in MOE chapter 3:

EASA wants to further improve the level of safety with respect to EASA Part-145 Approved Maintenance Organizations. The principles of safety management as indicated in the ICAO Annex 19 SARP’s will be fostered and the procedures for oversight and enforcement will be streamlined.

The safety risks introduced by the aviation industry must result in an Acceptable Level of Safety (or ALoS). Acceptable level means as long as safety risks and operational errors are kept under a reasonable degree of control, a system as open and dynamic as commercial civil aviation is considered to be safe. In other words, safety risks and operational errors that are controlled to a reasonable degree are acceptable in an inherently safe system.

The EASA system establishes at legislative level the safety objectives to be met by means of essential requirements. These requirements have been designed to mitigate any probable risk linked to civil aviation activities within the scope of the EASA system. These mitigating means will be further detailed in appropriate Part-145 Implementing Rules (IR), Acceptable Means of Compliance (AMC) and Guidance Material (GM).

So why do we need to implement SMS, besides complying with the EASA regulations?

Because, besides achieving Improved Safety, it will also result in Continuous Improvement of operational processes and Repetitive Common Cause Accidents will essentially be eliminated.

This can only be achieved when EASA Part-145 Approved Maintenance Organizations move from a reactive to a proactive and predictive approach towards safety risks.

Implementation of SMS also has financial benefits. Besides cost reduction and cost avoidance, it will also result in a reduction of the direct and indirect costs of accidents, incident investigation and operational disruptions.

And finally, implementing an effective SMS, will provide EASA Part-145 Approved Maintenance Organizations with a competitive benefit. That is as mentioned before because of the financial benefits, but also because a well matured SMS will result in establishing a marketable safety record.

Because we need input from you. Send us your question via the contact form on our website and we will work out and display an answer on this page.