Q: How many types of AFRA accreditations can I apply for?

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.

Q: How can my organisation become ASA accredited?

ASA has published the steps to become accredited here .

Question 1

Can I outsource parts of the AFRA BMP Accredication (Disassembly & Recycling)?

ACSG · Accepted Answer

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.

Question 2

How do you apply for an AFRA BMP accreditation?

ACSG · Accepted Answer

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.

Question 3

How many types of AFRA accreditations can I apply for?

ACSG · Accepted Answer

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.

Question 4

Is AS-9100 equivalent to the EN-9100?

ACSG · Accepted Answer

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

Question 5

What are the benefits of implementing a 9100 quality standard?

ACSG · Accepted Answer

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.

Question 6

What is an FAI?

ACSG · Accepted Answer

A first article inspection (FAI) is a planned, complete, independent, and documented inspection and verification process to ensure that prescribed production processes have produced an item conforming to engineering drawings, Digital Production Definition*, planning, purchase order, engineering specifications, and/or other applicable design documents.

Purpose of FAI's is to identify product realization processes that are not capable of producing conforming product, and initiate and/or validate corrective actions.

An FAI must be performed on new products that are representative of the first production cycle. The first parts for this production delivery require an FAI.

This process must be repeated if changes occur that (may) affect the original results (for example engineering changes, changes in the manufacturing process, changes in the tool).

Summarized: FAI is a validation method within the Production Process.

*e.g. 2D and 3D drawings or models

Image source: https://inspecco.com/

Question 7

What is AS/EN-9100?

ACSG · Accepted Answer

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.

Question 8

Is AS-9110 equivalent to the EN-9110?

ACSG · Accepted Answer

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

Question 9

What are the benefits of implementing a 9110 quality standard?

ACSG · Accepted Answer

• 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.

Question 10

Which organisations could potentially have a need of adopting the 9110 quality management standard?

ACSG · Accepted Answer

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

Question 11

Is AS-9120 equivalent to EN-9120?

ACSG · Accepted Answer

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

Question 12

What are the benefits of implementing a 9120 quality standard?

ACSG · Accepted Answer

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

Question 13

What is an FAI?

ACSG · Accepted Answer

A first article inspection (FAI) is a planned, complete, independent, and documented inspection and verification process to ensure that prescribed production processes have produced an item conforming to engineering drawings, Digital Production Definition*, planning, purchase order, engineering specifications, and/or other applicable design documents.

Purpose of FAI's is to identify product realization processes that are not capable of producing conforming product, and initiate and/or validate corrective actions.

An FAI must be performed on new products that are representative of the first production cycle. The first parts for this production delivery require an FAI.

This process must be repeated if changes occur that (may) affect the original results (for example engineering changes, changes in the manufacturing process, changes in the tool).

Summarized: FAI is a validation method within the Production Process.

*e.g. 2D and 3D drawings or models

Image source: https://inspecco.com/

Question 14

Which organisations could potentially have a need of adopting the 9120 quality management standard?

ACSG · Accepted Answer

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.

Question 15

How can my organisation become ASA accredited?

ACSG · Accepted Answer

ASA has published the steps to become accredited here.

Question 16

What is ASA-100?

ACSG · Accepted Answer

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.

Question 17

What sections of Title 49 of the Code of Federal Regulations (CFR) is applicable to ASA accredited distributors, in relation to the requirement of having a system in place that governs the control and transport of Hazardous Materials?

ACSG · Accepted Answer

General:

In revision 05 of the ASA-100 standard a new requirement is added, being:

15. The distributor shall have a system in place governing the control of hazardous material and transport of hazardous material that meets Title 49 of the Code of Federal Regulations (49 CFR).

This requirement was already detailed in FAA AC 00-56B and is now also included in the ASA-100 rev 05.

CFR 49 describes in Subchapter A the Hazardous Materials Program requirements related to transportation in Part 105 - 110.

CFR 49 describes in Subchapter B the requirements for Oil Spill prevention and response plans in Part 130.

CFR 49 describes in Subchapter C the Hazardaous Material Requirements in regards with handling and shipping (by Rail, Aircraft, Vessel or Public Highway) in Part 171 - 180.

Depending on the activities of your organisation and the parts or items that you organisation handles and ships, several requirements in Subpart A-C could be applicable to your business activities as an ASA accredited distributor.

We advise you to determine the applicability of each and every requirement in Subpart A-C and with that adjust or re-define your control system for HazMat handling and transportation.

Question 18

Where can I find the ASA-100 Standard and relevant documents?

ACSG · Accepted Answer

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

Question 19

How do foreign non-domestic Maintenance Organisations apply for CAAC Maintenance Organisation Certification (MOC)?

ACSG · Accepted Answer

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.

Question 20

What are the requirements for a foreign non-domestic organisation in regards with application for the CAAC Maintenance Organisation Certification (MOC)?

ACSG · Accepted Answer

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.

Question 21

What is the current revision of the CAAC's CCAR Part 145?

ACSG · Accepted Answer

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

Question 22

Where can I find the CAAC regulations and related Advisory Circulars related to Maintenance Organisation Certification (MOC)?

ACSG · Accepted Answer

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

Question 23

Can a B-rated EASA Part-145 'Engine shop' remove Engines (in serviceable condition) from Aircraft and certify them with an EASA Form-1?

ACSG · Accepted Answer

If it is from an aircraft that is still in service, you need to have an A-rating (aircraft maintenance) , so NO.

If the aircraft is withdrawn from service and being dismantled, it is also NOT possible that a B-rated 'Engine Shop' issues an EASA From 1 for removal of serviceable engines, as AMC2 145.A.50(d) details the following:

(a) Aircraft withdrawn from service are sometimes dismantled for spares. This is considered to be a maintenance activity and should be accomplished under the control of an organisation approved under Part-145, employing procedures approved by the competent authority.

(b) To be eligible for installation, components removed from such aircraft may be issued with an EASA Form 1 by an appropriately rated organisation following a satisfactory assessment.

In this case, appropriatelly rated organisation means an A-rated (aircraft maintenance) organisation.

The only option for a B-rated 'Engine shop' to issue a Form-1 for an engine is to receive the engine in the Engine Shop and perform a Inspection/Test.

Question 24

Can an EASA Part-145 / Part-M Subpart F approved maintenance organisation fabricate their own parts?

ACSG · Accepted Answer

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.

Question 25

Do you have to acquire experience inside an EASA Part-145 Approved Maintenance Organisation?

ACSG · Accepted Answer

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.

Question 26

How do you correct a Certificate of Release to Service (CRS)?

ACSG · Accepted Answer

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:

basic lay-out of the maintenance carried out;
the date on which the maintenance was completed;
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;
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.

Question 27

How should you implement SMS requirements in a Part-145 Maintenance Organisation?

ACSG · Accepted Answer

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.

Question 28

If you are a both Part-M and 145 organisation, is it also then required that you show your compliance for Part 66?

ACSG · Accepted Answer

Yes and No.

Yes, if you maintain Aircraft

No, when you maintain Aircaft Components (including APU and Engines). For this we refer to Article 5, 6. Of the Cover regulation, EU 1321/2014.

“Until specific requirements for certifying staff for components are added to this Regulation, the requirements laid down in the national laws in force in the relevant Member State shall continue to apply, except for maintenance organisations located outside the Union where there quirements shall be approved by the Agency."

EASA Part 66 is all about licensing of aircraft maintenance staff.
To perform part-145 approved maintenance work or in other words; Able to certify the work (CRS - Certificate of Release to Service) you need Part-66 licensed staff.

A Part-66 Maintenance License is a personal document (like a drivers license) and forms the basis for a company approval. The both form the basis for certification authorisation, issue a CRS.

Second; Part-66 also defines the privileges of the Maintenance License regarding aircraft type and rating (B1 = Airframe , Powerplant. B2= Avionics)

Question 29

If you are going to work for another EASA Part-145, does your EASA Part-66 AML remain valid?

ACSG · Accepted Answer

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.

Question 30

Is it allowed to issue one EASA form 1 for multiple different part numbers?

ACSG · Accepted Answer

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).

Example 1 of 2: Multiple PN's on an EASA Form-1 (new produced)

Example 2 of 2: Multiple PN's on an EASA Form-1 (new produced)

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.

Example 1 of 1: Multiple PN's on an EASA Form-1 (used parts)

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

Question 31

Is it allowed to remove components or engines from an aircraft for maintenance purposes and install them back under an EASA Part-145 Class A1 rating?

ACSG · Accepted Answer

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:

Question 32

Is it required by EASA Part-145 to have a Foreign Object Debris (FOD) control program?

ACSG · Accepted Answer

No, there is no direct FOD programme requirement in EASA Part-145, but the impact by contamination and dust is detailed in EASA Part-145.A.25 (a) and (c).

EASA Part-145.A.25 (a) requires that the facility should be protected from the wheather elements and Specialised workshops and bays should be segregated to avoid work area contamination.

EASA Part-145.A.25 (c) 2. specifies the following:

Dust and any other airborne contamination are kept to a minimum and not be permitted to reach a level in the work task area where visible aircraft/component surface contamination is evident. Where dust/other airborne contamination results in visible surface contamination, all susceptible systems are sealed until acceptable conditions are re-established.

A program to control FOD is most effective when includes training. All personnel should receive training in the identification and elimination of FOD, including the potential consequences of ignoring it. Effective training include procedures for removing and eliminating FOD at its source, and should be reinforced through the use of posters and signs. Recurrent training is necessary to help maintain an awareness of FOD.

Question 33

Is it required to indicate "Duplicate" or "Copy" on a non-original EASA form 1?

ACSG · Accepted Answer

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.

Question 34

Is it required to physically separate Part-21 stock from Part-145 stock?

ACSG · Accepted Answer

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.

Question 35

What is a Complex Motor Powered Aircraft (CMPA)?

ACSG · Accepted Answer

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;

Question 36

What is Release Privilege?

ACSG · Accepted Answer

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.

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.

Question 37

What will be the upcomming changes to Human Factors training requirements for EASA Part-145 organisations?

ACSG · Accepted Answer

According to NPA 2019-05 and with the introduction of SMS, Human Factors training will be included in Safety Training.

The course syllabus for Safety Training is proposed to become*:

General/Introduction to safety management and human factors
1.1. Need to address safety management and human factors
1.2. Statistics
1.3. Incidents
1a. Safety risk management
1a.1. Hazard identification
1a.2. Safety risk assessment
1a.3. Risk mitigation and management
1a.4. Effectiveness of safety risk management
Safety Culture/Organisational factors
2.1 Just culture
2.2 Reporting culture
2.3 Informed culture
2.4 Flexible culture/learning culture
Human error
3.1. Error models and theories
3.2. Types of errors in maintenance tasks
3.3. Violations
3.4. Implications of errors
3.5. Avoiding and managing errors
3.6. Human reliability
Human performance & limitations
4.1. Vision
4.2. Hearing
4.3. Information-processing
4.4. Attention and perception
4.5. Situational awareness
4.6. Memory
4.7. Claustrophobia and physical access
4.8. Motivation
4.9. Fitness/Health
4.10. Stress
4.11. Workload management
4.12. Fatigue and fatigue risk management
4.13. Alcohol, medication, drugs
4.14. Physical work
4.15. Repetitive tasks/complacency
Environment
5.1. Peer pressure
5.2. Stressors
5.3. Time pressure and deadlines
5.4. Workload
5.5. Shift Work
5.6. Noise and fumes
5.7. Illumination
5.8. Climate and temperature
5.9. Motion and vibration
5.10. Complex systems
5.11. Other hazards in the workplace
5.12. Lack of manpower
5.13. Distractions and interruptions
Procedures, information, tools and practices
6.1. Visual Inspection
6.2. Work logging and recording
6.3. Procedure - practice/mismatch/norms
6.4. Technical documentation - access and quality
6.5. Critical maintenance tasks and error-capturing methods (independent inspection,
reinspection, etc.)
Communication
7.1. Shift/Task handover
7.2. Dissemination of information
7.3. Cultural differences
Teamwork
8.1. Responsibility
8.2. Management, supervision and leadership
8.3. Decision-making
Professionalism and integrity
9.1. Keeping up to date; currency
9.2. Avoiding Error-provoking behaviour
9.3. Assertiveness
Organisation’s safety programme
10.1. Safety policy and objectives, just culture principles
10.2.Reporting errors and hazards, internal safety reporting scheme
10.3. Occurrence investigation process
10.4. Action to address problems
10.5. Feedback and safety promotion

* Changes are indicated in Italic

Question 38

What will change for EASA Part-145 Approved Maintenance Organisations from EASA NPA 2019-05 (A) & (C) (Implementation of SMS)?

ACSG · Accepted Answer

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:

Question 39

Which logbook should I use?

ACSG · Accepted Answer

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.

Question 40

Why do we need to implement SMS in EASA Part-145 approved organisations?

ACSG · Accepted Answer

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.

Question 41

Is it allowed to issue one EASA form 1 for multiple different part numbers?

ACSG · Accepted Answer

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.

Question 42

Is it required to physically separate Part-21 stock from Part-145 stock?

ACSG · Accepted Answer

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.

Question 43

Why are there no Questions displayed here?

ACSG · Accepted Answer

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.

Question 44

An EASA Part-147 approved Maintenance Training Organisation, what does that mean?

ACSG · Accepted Answer

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.

Question 45

Can an EASA Part-66 Aircraft Maintenance Licence (or AML) expire?

ACSG · Accepted Answer

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

Question 46

Do you have to acquire experience inside an EASA Part-145 Approved Maintenance Organisation?

ACSG · Accepted Answer

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.

Question 47

How often am I allowed to (re)take and EASA Part66 module examination?

ACSG · Accepted Answer

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.

Question 48

I have Basic Examination Certificates of Recognition (COR's) issued in 2009. Are these still valid?

ACSG · Accepted Answer

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).

Question 49

If you are going to work for another EASA Part-145, does your EASA Part-66 AML remain valid?

ACSG · Accepted Answer

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.

Question 50

What am I allowed to bring to an EASA Part-66 Module Examination?

ACSG · Accepted Answer

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.

Question 51

What impact does Brexit have in regards with “Certificate of Recognition” issued by a UK based Part-147 Organisation?

ACSG · Accepted Answer

A “Certificate of Recognition” issued by a UK based Part-147 Organisation.

2 months have passed after Brexit and the consequences are becoming very clear.

EASA had now published guidance, simply stating that all Certificates of Recognition issued by UK based Part-147 organisation are declared void (in EASA member states). Except for newly issued COR’s after 1-Jan-2021 by foreign EASA Part-147 in the UK, which successfully completed the Brexit early application process.

The UK CAA has issued information to licensed engineers, in which basically they are stating “everything is fine, you can apply for a UK-CAA Part-66 AML”.

Some example and the consequences; if a person (with an EASA AML) has done a Type Training at a UK-CAA and has received the “Certificate of Recognition”, but has not endorsed the Aircraft Type on the Part-66 => the person must do the complete training again. The Certificate will no longer have a value for EASA member state authorities.

Technicians, who have successfully passed the Basic Module Examinations, with for example the Resource Group or AST, can apply for a UK-CAA Part-66 AML. The certificate is no longer valid in Europe.

Let’s hope that UK-CAA and EASA can reach an agreement, but we regard these changes is being very small.

Question 52

What is an AML?

ACSG · Accepted Answer

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.

Question 53

What is an approved EASA Part-66 Basic Training course?

ACSG · Accepted Answer

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.

Question 54

What is Release Privilege?

ACSG · Accepted Answer

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.

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.

Question 55

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

ACSG · Accepted Answer

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.

Question 56

Which logbook should I use?

ACSG · Accepted Answer

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.

Question 57

Is there a difference between CAMO (part of Part-OPS) and a CAMO Plus?

ACSG · Accepted Answer

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.

Question 58

What is a Complex Motor Powered Aircraft (CMPA)?

ACSG · Accepted Answer

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;

Question 59

What is EASA Part-CAMO?

ACSG · Accepted Answer

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

Question 60

What is a Complex Motor Powered Aircraft (CMPA)?

ACSG · Accepted Answer

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;

Question 61

What is EASA Part-CAO?

ACSG · Accepted Answer

Part-CAO is combined CAMO with Maintenance.

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

Question 62

Can an EASA Part-145 / Part-M Subpart F approved maintenance organisation fabricate their own parts?

ACSG · Accepted Answer

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.

Question 63

How do you correct a Certificate of Release to Service (CRS)?

ACSG · Accepted Answer

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:

basic lay-out of the maintenance carried out;
the date on which the maintenance was completed;
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;
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.

Question 64

If you are a both Part-M and 145 organisation, is it also then required that you show your compliance for Part 66?

ACSG · Accepted Answer

Yes and No.

Yes, if you maintain Aircraft

No, when you maintain Aircaft Components (including APU and Engines). For this we refer to Article 5, 6. Of the Cover regulation, EU 1321/2014.

“Until specific requirements for certifying staff for components are added to this Regulation, the requirements laid down in the national laws in force in the relevant Member State shall continue to apply, except for maintenance organisations located outside the Union where there quirements shall be approved by the Agency."

EASA Part 66 is all about licensing of aircraft maintenance staff.
To perform part-145 approved maintenance work or in other words; Able to certify the work (CRS - Certificate of Release to Service) you need Part-66 licensed staff.

A Part-66 Maintenance License is a personal document (like a drivers license) and forms the basis for a company approval. The both form the basis for certification authorisation, issue a CRS.

Second; Part-66 also defines the privileges of the Maintenance License regarding aircraft type and rating (B1 = Airframe , Powerplant. B2= Avionics)

AFRA BMP

Can I outsource parts of the AFRA BMP Accredication (Disassembly & Recycling)?

How do you apply for an AFRA BMP accreditation?

How many types of AFRA accreditations can I apply for?

AS/EN-9100

Is AS-9100 equivalent to the EN-9100?

What are the benefits of implementing a 9100 quality standard?

What is an FAI?

What is AS/EN-9100?

AS/EN-9110

Is AS-9110 equivalent to the EN-9110?

What are the benefits of implementing a 9110 quality standard?

Which organisations could potentially have a need of adopting the 9110 quality management standard?

AS/EN-9120

Is AS-9120 equivalent to EN-9120?

What are the benefits of implementing a 9120 quality standard?

What is an FAI?

Which organisations could potentially have a need of adopting the 9120 quality management standard?

ASA-100

How can my organisation become ASA accredited?

What is ASA-100?

What sections of Title 49 of the Code of Federal Regulations (CFR) is applicable to ASA accredited distributors, in relation to the requirement of having a system in place that governs the control and transport of Hazardous Materials?

Where can I find the ASA-100 Standard and relevant documents?

CAAC CCAR Part 145

How do foreign non-domestic Maintenance Organisations apply for CAAC Maintenance Organisation Certification (MOC)?

What are the requirements for a foreign non-domestic organisation in regards with application for the CAAC Maintenance Organisation Certification (MOC)?

What is the current revision of the CAAC’s CCAR Part 145?

Where can I find the CAAC regulations and related Advisory Circulars related to Maintenance Organisation Certification (MOC)?

EASA Part-145

Can a B-rated EASA Part-145 ‘Engine shop’ remove Engines (in serviceable condition) from Aircraft and certify them with an EASA Form-1?

Can an EASA Part-145 / Part-M Subpart F approved maintenance organisation fabricate their own parts?

Do you have to acquire experience inside an EASA Part-145 Approved Maintenance Organisation?

How do you correct a Certificate of Release to Service (CRS)?

How should you implement SMS requirements in a Part-145 Maintenance Organisation?

If you are a both Part-M and 145 organisation, is it also then required that you show your compliance for Part 66?

If you are going to work for another EASA Part-145, does your EASA Part-66 AML remain valid?

Is it allowed to issue one EASA form 1 for multiple different part numbers?

Is it allowed to remove components or engines from an aircraft for maintenance purposes and install them back under an EASA Part-145 Class A1 rating?

Is it required by EASA Part-145 to have a Foreign Object Debris (FOD) control program?

Is it required to indicate “Duplicate” or “Copy” on a non-original EASA form 1?

Is it required to physically separate Part-21 stock from Part-145 stock?

What is a Complex Motor Powered Aircraft (CMPA)?

What is Release Privilege?

What will be the upcomming changes to Human Factors training requirements for EASA Part-145 organisations?

* Changes are indicated in Italic

What will change for EASA Part-145 Approved Maintenance Organisations from EASA NPA 2019-05 (A) & (C) (Implementation of SMS)?

Which logbook should I use?

Why do we need to implement SMS in EASA Part-145 approved organisations?

EASA Part-21 Sub-G

Is it allowed to issue one EASA form 1 for multiple different part numbers?

Is it required to physically separate Part-21 stock from Part-145 stock?

EASA Part-21 Sub-J

Why are there no Questions displayed here?

EASA Part-66/147

An EASA Part-147 approved Maintenance Training Organisation, what does that mean?

Can an EASA Part-66 Aircraft Maintenance Licence (or AML) expire?

Do you have to acquire experience inside an EASA Part-145 Approved Maintenance Organisation?

How often am I allowed to (re)take and EASA Part66 module examination?

I have Basic Examination Certificates of Recognition (COR’s) issued in 2009. Are these still valid?

If you are going to work for another EASA Part-145, does your EASA Part-66 AML remain valid?

What am I allowed to bring to an EASA Part-66 Module Examination?

What impact does Brexit have in regards with “Certificate of Recognition” issued by a UK based Part-147 Organisation?

What is an AML?

What is an approved EASA Part-66 Basic Training course?

What is Release Privilege?

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

Which logbook should I use?

EASA Part-CAMO

Is there a difference between CAMO (part of Part-OPS) and a CAMO Plus?

What is a Complex Motor Powered Aircraft (CMPA)?

What is EASA Part-CAMO?

EASA Part-CAO

What is a Complex Motor Powered Aircraft (CMPA)?

What is EASA Part-CAO?

EASA Part-M

Can an EASA Part-145 / Part-M Subpart F approved maintenance organisation fabricate their own parts?

How do you correct a Certificate of Release to Service (CRS)?

If you are a both Part-M and 145 organisation, is it also then required that you show your compliance for Part 66?

Is it required to indicate “Duplicate” or “Copy” on a non-original EASA form 1?

Is there a difference between CAMO (part of Part-OPS) and a CAMO Plus?