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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.
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.
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)
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;
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