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Can a B-rated EASA Part-145 ‘Engine shop’ remove Engines (in serviceable condition) from Aircraft and certify them with an EASA Form-1?
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If the aircraft is withdrawn from service and being dismantled, it is also NOT possible that a B-rated ‘Engine Shop’ issues an EASA From 1 for removal of serviceable engines, as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(a) Aircraft withdrawn from service are sometimes dismantled for spares.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.
Can an EASA Part-145 / Part-M Subpart F approved maintenance organisation fabricate their own parts?
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:
- 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.
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.
If you are a both Part-M and 145 organisation, is it also then required that you show your compliance for Part 66?
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)
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.
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?
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 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.
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.
What will be the upcomming changes to Human Factors training requirements for EASA Part-145 organisations?
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
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
3.4. Implications of errors
3.5. Avoiding and managing errors
3.6. Human reliability
- Human performance & limitations
4.4. Attention and perception
4.5. Situational awareness
4.7. Claustrophobia and physical access
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
5.1. Peer pressure
5.3. Time pressure and deadlines
5.5. Shift Work
5.6. Noise and fumes
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,
7.1. Shift/Task handover
7.2. Dissemination of information
7.3. Cultural differences
8.2. Management, supervision and leadership
- Professionalism and integrity
9.1. Keeping up to date; currency
9.2. Avoiding Error-provoking behaviour
- 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
What will change for EASA Part-145 Approved Maintenance Organisations from EASA NPA 2019-05 (A) & (C) (Implementation of SMS)?
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.
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