New CAW regulatory framework What changes for us? - Your safety is our mission - Enac

 
New CAW regulatory framework What changes for us? - Your safety is our mission - Enac
New CAW regulatory framework
                    What changes for us?
                        ENAC workshop 13 Nov 2019

Eugenia Diaz Alcazar
Airworthiness Standards & Implementation Section Manager
                                               Your safety is our mission.
                                                      An Agency of the European Union
Content
→ General overview of recent changes to CAW regulation
→ 1st part – Changes due to SMS
  → Part-CAMO
  → Introduction of SMS in Part-145

→ 2nd part – Other changes
  → General Aviation
  → Maintenance Check lights and Mixed Operation

                                                         2
Reg (EU) 1321/2014
                       Reg (EU) 2019/1383
→ GA Task Force Phase II (Opinion 05/2016)
  → Part-ML
  → Part-CAO (without SMS)
→ SMS Phase I (Opinion 06/2016)
  → Part-CAMO (with SMS)
  → Part-M
→ Technical Records (Opinion 13/2016)
                       Reg (EU) 2019/1384
→ Mixed Operations & Maintenance Check Flights
                                                 3
Reg (EU) 1321/2014 – new structure
                 Background and general overview
 → Opinions voted 28 Feb 2019
 → Regulation (EU) 2019/1383
  →   Adopted:          8 Jul 2019
  →   Published in OJ: 4 Sep 2019
  →   Entry into force: 24 Sep 2019
  →   Applicable from: 24 Marc 2020 (cf. corrigendum)
  →   Also Part-M/-145/-66/-147/-T affected
  →   Transition period

                                                        4
Reg (EU) 1321/2014 – new structure

                                     5
Part-CAMO (1/13)
                        Why SMS?
 →Air Operators are required to implement a Management
  System including safety management processes (Reg.
  (EU) 965/2012)
 →Licenced air carrier operators are required to be
  approved as CAMO (Reg. (EU) 1321/2014)
 →+ ICAO Annex 19 compliance
      Management System required for CAMO
                                                    6
Part-CAMO (2/13)      General approach
  →New Annex Vc – Part-CAMO
  →New structure, new numbering based on ARX/ORX (Air
     Operation and Air Crew Regulations) with content
     adapted to CAMO
  →Introduction of a «Management system», including SMS
     and Compliance Monitoring (references to ‘quality
     system’ are deleted)
  →Keep Section A and Section B
Part-M Subpart G approvals no longer valid from 24 Sep 21
                                                      7
Part-CAMO (3/13)
                   General approach
 →CAMO required for continuing airworthiness
  management of:
  → Complex motor-powered a/c (twin-turboprop < 5700 kg
    MTOM ‘exempted’); and/or
   → Aircraft operated by licenced air carriers;
 →May be used for all other a/c (optional)

                                                          8
Part-CAMO (4/13)
             SECTION A – ORGANISATION REQUIREMENTS
    → General requirements
    CAMO.A.005 Scope                          ORX.GEN
    to                                        Section 1
    CAMO.A.160 Occurrence reporting

    → Management
    CAMO.A.200 Management system                 ORX.GEN
    to                                           Section 2
    CAMO.A.220 Record keeping

    → CAMO specific requirements                   CAMO
    CAMO.A.300 Continuing airworthiness managementspecific
                                                   exposition
    to
    CAMO.A.325 Continuing airworthiness management data         9
Part-CAMO                  From ‘Quality system’ to ‘Management system’
   M.A.712 Quality system                     CAMO.A.200 Management system
                                              (CAMO.A.202/205)

   Main focus:                                Main focus:
   Compliance monitoring                      Safety risk management
   Feedback system                            Effectiveness of mitigating actions
                                              Compliance monitoring
   In case of licensed air carriers           In case of licensed air carriers the
   the quality system shall be an             management system shall be an
   integral part of the operator’s            integral part of the operator’s
   quality system                             management system
   Organisational review for small            No organisational review – Compliance
   CAMOs managing a/c not used                Monitoring function required in all
   by licenced air carrier                    cases
                                                                                      10
Part-CAMO (6/13)
 → CAMO.A.200 focuses on what is essential for safety management,
   by mandating the organisation to:
   → responsibilities
   → safety policy
   → safety reporting procedures (just culture principles)
   → identification of safety hazards and the management of associated risks
     including actions to mitigate those risks and effectiveness of those actions
   → monitor compliance
   → competent personnel informed about significant safety issues
   → document

                                                                               11
Part-CAMO (7/13)
 →SMS is simple for simple organisation/activity
 →An effective SMS can be demonstrated by answering
  4 simple questions:
   1.   What is most likely to be the cause of your next occurrence with the
        potential to lead to an accident or serious incident?
   2.   How do you know that?
   3.   What are you doing about it?
   4.   Is it working?

                                                                               12
Part-CAMO (8/13)
 CAMO oversight cycle by Competent Authority
 →Harmonised oversight among the aviation domains and
   risk based oversight approach
 →Credit may be taken from the Management system
Effective risk management             “Effective continuous reporting system to
Change management                     competent authority on safety performance and
Corrective actions implemented        regulatory compliance”

        24 months                36 months          48 months
                          Level 1           Reduced safety
                          finding           performance                               13
Part-CAMO (9/13)                 AMC/GM
 → Unlike for aircrew and air operations, no distinction will be made
   between complex and non-complex organisations
 → Flexibility and proportionality will be provided (e.g. for small
   organisation) in a single set of AMC
  → Example: Establishment of a safety review board (SRB) except where not
    justified by the size of the organisation and the nature and complexity of its
    activities
 → References to ‘EASA Form 4’ to be deleted for all management
   personnel. Acceptance process through oversight and exposition
   approval
                                                                                14
Part-CAMO (10/13)       Also new in Part-CAMO
  →Occurrence reporting iaw Reg. (EU) 376/2014
  →Internal safety reporting scheme to enable the collection
   and evaluation of all occurrences, errors, hazards etc.
  →New Part-CAMO applicants shall perform a pre-audit
  →Possibility for the organisation to develop ‘Alternative
   Means of Compliance’ (AltMoC to the EASA AMC)
  →Concept of ‘Change not requiring prior approval’
   replacing ‘Indirect approval’ (same intent)
  →System to plan the availability of staff              15
Part-CAMO (11/13)        Transition
  →Organisations holding Part-M Subpart G approval will be
   deemed to have been approved in accordance with Part-
   CAMO
  →They will be given 2 years to adapt their procedures and
   exposition to be compliant with Part-CAMO
  →They will then receive a new EASA Form 14 (issue 5)
   CAMO approval Certificate
  →Until the organisation complies with Part-CAMO,
   oversight in accordance with Subpart G of Part-M
                                                        16
Part-CAMO (12/13)                             Transition
  24 Sep 2019        24 March 2020                                        24 Sep 2021

                                   Deemed to be approved by Part-CAMO (no NEW        Subpart G certificate
                                                   certificate)                      revoked if transition
                                                                                     findings not closed !

  Subpart G     Subpart G                   Deemed Part-CAMO                 Compliant Part-CAMO
                                                                             Surveillance iaw Part-
                   Surveillance i.a.w. Part-M Subpart G
                                                                                     CAMO

                                           Closure “transition finding”

                                                                                   Issuance CAMO
                                                          CAME                        certificate
                                                          approved
                                                                                                        17
Part-CAMO
  24 Sep 2019
               (13/13)
              24 March 2020                                                   24 Sep 2021

                                    Request Part-CAMO certificate
                                                                                          CAMO revoked if
                                                                                          not in compliance
                                                           Issuance new CAMO              with Part-CAMO!
  Subpart G           Subpart G                                 certificate

     Surveillance i.a.w. Supart G                         Surveillance i.a.w. Part-CAMO

                                         Closure “transition finding” Part-CAMO

              Transition - Possible amendment to regulation!                                              18
Part-145 with SMS (1/9)
 → Working method RMT.0251(b)
  → Content harmonised with Part-CAMO and
    Part-ARX/ORX (Air Operation and Air Crew Regulations)
  → Introduction of a « Management system »
      → Aligned with Part-CAMO
      → includes Safety management and Compliance Monitoring (references to ‘quality system’ are
        deleted)
      → for all Part-145 organisations
 → Streamlined approach to Part-145 amendments:
  → Section A (organisation requirements): any existing/amended paragraph keeps
    the current numbering; any ‘new’ paragraph takes the Part-CAMO numbering
  → Section B (authority requirements): alignment with Part-CAMO

                                                                                                   19
Part-145 with SMS (2/9) – NPA 2019-05(C)

                                           20
Part-145 with SMS (3/9) – NPA 2019-05(C)

                                           21
Part-145 with SMS (4/9) – NPA 2019-05(C)

                                           22
Part-145 with SMS (5/9) – NPA 2019-05(C)

                                           23
Part-145 with SMS (6/9)
 → 145.A.200 focuses on what is essential for safety management, by mandating
   the organisation to:
   →   clearly define responsibilities and accountabilities
   →   establish a safety policy and related safety objectives
   →   implement safety reporting procedures in line with just culture principles
   →   ensure the identification of aviation safety hazards entailed by its activities, ensure their
       evaluation, and the management of associated risks including:
       → taking actions to mitigate the risks;
       → verifying the effectiveness of actions taken to mitigate risks;
   →   monitor compliance, while considering any additional requirements that are applicable
       to the organisation
   →   maintain personnel trained, competent, and informed about significant safety issues
   →   document all management system key processes.

                                                                                                  24
Part-145 with SMS (7/9)
                                     AMC/GM
 → Unlike for aircrew and air operations no distinction between complex
   and non-complex organisations
 → Flexibility and proportionality will be provided (e.g. for small organisation)
   in a single set of AMC (same approach as CAMO)
   → Example: Establishment of a safety review board (SRB) except where not
     justified by the size of the organisation and the nature and complexity of its
     activities
 → References to personnel ‘human factor training’ replaced by ‘safety
   training’
 → Management of change, continuous improvement, internal
   investigation

                                                                                      25
Part-145 with SMS (8/9)
                          Other changes not SMS related
 →   References to Reg. (EC) No 216/2008 changed to Reg. (EU) 2018/1139
     (New Basic Regulation)
 →   Concept of ‘change not requiring prior approval’ replacing ‘indirect
     approval’ (same intent) see 145.A.85
 →   References to Flight Engineer (FE) licences deleted, as these are no
     longer foreseen in EASA Part-FCL. Existing authorisations to be
     ‘grandfathered’
 →   Pre-audit required for new Part-145 applicants
 →   References to EASA Form 4 in AMC deleted for all management
     positions (same approach as CAMO). Acceptance process through oversight
     and exposition approval

                                                                           26
Part-145 with SMS (9/9)
                            Transition
 → Under discussion - Part-145 organisations may be given 2
   years to adapt their procedures and exposition
   → With the management system requirement
   → With the other changes to Part-145
                           Conclusion
 → This proposal addresses the core elements of the ICAO
   Annex 19 and promotes an integrated approach to the
   management of an organisation

                                                              27
Reg (EU) 1321/2014 – new structure

                                     28
Part-ML (1/19)
               What is « Part-M light » (Part-ML)?
 → Part-ML objectives:
  → proportional to lower complexity and associated risks,
  → as clear and simple as possible.

           Part-ML similar in its structure to Part-M

 → How? Alleviations in AMP, Airworthiness Review, defect
   deferment by pilot …
                                                             29
Part-ML (2/19)
 → Applicability to non-complex:
   → Aeroplanes up to 2 730 Kg MTOM
   → Helicopters up to 1 200 kg MTOM / max 4 occupants
   → Other ELA 2 aircraft
   When they are not used by Licenced Air Carrier (LAC)
 → Part-ML is the only option for this category of aircraft.
 → All other aircraft must follow Part-M

     Part-ML covers both private and commercial (non-LAC),
             in particular all sailplanes and balloons
                                                               30
Part-ML (3/19)
           Continuing Airworthiness Management

    * CAMO or CAO(-CAM) may be optionally contracted by the owner

                                                                    31
Part-ML (4/19)
           Continuing Airworthiness Management

    * CAMO or CAO(-CAM) may be optionally contracted by the owner

                                                                    32
Part-ML (5/19)
           Continuing Airworthiness Management

                        Case of ATO/DTO

    * CAMO or CAO(-CAM) may be optionally contracted by the owner

                                                                    33
Part-ML (6/19)
           Continuing Airworthiness Management

   When a CAMO or CAO(-CAM) is not contracted, the owner
   shall manage the continuing airworthiness of the aircraft
   under its own responsibility.

          When the aircraft is leased, the responsibility is
                    transferred to the lessee.

                                                               34
Part-ML (7/19)
            Aircraft Maintenance Programme (AMP) New!
  → Not possible to have the AMP approved by NAA
  → For aircraft managed by a CAMO or CAO:
   → The CAMO or CAO approves the AMP with justifications to any
       deviations from Design Approval Holder (DAH) data
  → For aircraft not managed by a CAMO or CAO:
   → The AMP is declared by the owner (no justification for
       deviations needed)
       Remark: the NAA may still require a copy of the AMP

                                                             35
Part-ML (8/19)
                           AMP and MIP
  → Possibility to use the Minimum Inspection Programme (MIP) as an
    alternative to the DAH data
  → Possibility to deviate from DAH data, but the deviating task
    cannot be less than the extent of the corresponding MIP task in
    terms of frequency and task type

         Remark: no MIP for airships and rotorcraft to date

                                                                36
Part-ML         AMP and MIP examples in GM
    ICA task          AMP proposed           MIP task        Alternative
                      alternative                            acceptable
    Inspection XX     Inspection XX          Inspection XX   YES
    6 months          12 months interval     12 months
    interval                                 interval
    Inspection XX     Inspection XX          Inspection XX   NO
    12 months         24 months interval     12 months
    interval                                 interval

    Functional test   Operational test       Functional test NO (functional
    system XX         system XX (same        system XX       test considered
                      interval) or general   (same interval) more restrictive
                      visual inspection                      than operational
                      system XX (same                        test)
                                                                                37
                      interval)
Part-ML (10/19)
                              AMP review
 →AMP shall be reviewed annually:
  → in conjunction with the Airworthiness Review (AR), by the person
    performing the AR; or
  → by the CAMO or CAO(-CAM) (e.g. in case of ARC extension)
 →In case of deficiency found, the AMP shall be amended
     In case of deficiency, the Competent Authority shall be
      informed by the person performing the review only if
         he/she does not agree with the AMP corrections
                                                                       38
Part-ML (11/19)
         Acceptable Means of Compliance for AMP
 →Improved template for the AMP
 →Guidance on TBO extensions
 →Minimum Inspection Programme (MIP) compliant with
  ML.A.302(d) for aeroplanes, sailplanes and balloons
        The AMP template will be an “EASA Form AMP”

                                                        39
Part-ML (12/19)              AMP
 → New! no AMP declaration/approval and no AMP document
   required when:
    →The manufacturer data and all recommendations are
     used
    →No additional tasks resulting from repairs, modifications,
     life-limited components, repetitive ADs, etc.
    →Pilot-owner authorised for pilot-owner maintenance
         Note: the AMP will consist of relevant ICA, ALS, AD,
              service letters, operational requirements…
       Applicable also when CAMO or CAO(-CAM) is contracted     40
Part-ML (13/19)      Aircraft defects
 →New! Possibility for the pilot to defer:
→ defects affecting ‘non-required equipment’
→ defects affecting ‘required equipment’:
    →without the intervention of certifying staff
    →without using the MEL
    →when agreed with aircraft owner or contracted CAMO or CAO
   only for aircraft (other than balloon/sailplane) operated under Part-NCO
   only for balloon not operated under Subpart-ADD of Part-BOP
   only for sailplane not operated under Subpart-DEC of Part-SAO
                                                                              41
Part-ML (14/19) Component maintenance
 → Clarified/extended alleviation to release comp. maintenance
   with aircraft CRS (without EASA Form 1)
         iaw component maintenance data (e.g. CMM)
  → for:
      →Component maintenance other than overhaul
      →Overhaul of engine/propellers for CS-VLA, CS-22 and LSA
            iaw aircraft maintenance data (e.g. AMM)
  → for:
      →All component and all types of maintenance

                                                                 42
Part-ML (15/19)         Pilot-owner maintenance
  only for aircraft (other than balloon/sailplane) operated under Part-NCO
  only for balloon not operated under Subpart-ADD of Part-BOP
  only for sailplane not operated under Subpart-DEC of Part-SAO

    →Appendix II (replacing Appendix VIII) for tasks excluded
    →Possibility for the pilot-owner to release 100h/annual
     inspection task(s) when
      → the 100h/annual inspection is not combined with the
        Airworthiness Review
      → the task is not critical, complex, AD-related…                       43
Part-ML    Airworthiness Review (AR) and ARC
→Only EASA Form 15c applicable to Part-ML (by
 competent authority, organisation or independent CS)
→The Competent Authority may still perform the AR and
 issue the ARC
→The AR shall include a review of the AMP by the person
 performing the AR (extension: AMP reviewed by
 organisations)
 New! No more ARC recommendation to the Competent Authority
                                                          44
Part-ML (17/19)     AR and ARC (cont’d)
 →Possibility for maintenance organisations to perform AR
  and issue the ARC together with the 100h/annual
  inspection (before only possible for ELA1)
 →New! Possibility for independent certifying staff to
  perform AR and issue the ARC together with the
  100h/annual inspection
   only for aircraft (other than balloon/sailplane) operated under Part-NCO
   only for balloon not operated under Subpart-ADD of Part-BOP
   only for sailplane not operated under Subpart-DEC of Part-SAO
                                                                              45
Part-ML (18/19)
                ARC extension
→CAMO or CAO(-CAM) can extend max. 2 times the ARC
 if:
  → The aircraft has been managed by that CAMO or CAO during
    the last 12 months
  → Aircraft has been maintained during the last 12 months by:
     →Approved maintenance organisation; and/or
     →Pilot-owner iaw ML.A.803; and/or
     →Independent certifying staff carrying out pilot-owner maintenance tasks

                                                                                46
Part-ML (19/19)
                     Part-ML -> Part-M
 →If an aircraft moves from Part-ML to Part-M (e.g.
   because it changes to LAC operations):
  → The AMP must be approved by the NAA
  → Additional maintenance may be required to comply with the
    new AMP
  → An airworthiness review is performed and a new ARC is issued

                                                               47
Part-CAO (1/12)
 → Combined Airworthiness Organisation
 → New simplified organisation approval for GA
 → Alleviated requirements
 → Reduced involvement of Competent Authority
 → Combined privileges for:
  →   Maintenance
  →   Continuing airworthiness management
  →   Airworthiness review
  →   Permit to fly

                                                 48
Part-CAO (2/12)

                  49
Part-CAO (3/12)
 → Part-CAO applicable to :
  → Non-complex motor-powered aircraft
  → When they are not operated by licenced air carriers

       This covers Part-ML a/c and certain Part-M a/c

 → No SMS requirement (keeping ‘Quality System’)
 → Possibility to apply for a Part-CAO approval with partial privileges
 → Single exposition for all activities (CAE)
  Part-M Subpart F approvals no longer valid 2 years after entry into force
                                                                              50
Part-CAO (4/12)
                       Simple requirements
 → The approval certificate has been simplified, with no indication of
   aircraft types, just aircraft categories and associated privileges
 → No man-hour requirement
 → No requirement to record the recency of certifying staff
 → No minimum age for certifying staff

Small CAO can replace the quality system by regular organisational reviews
               (subcontracting of CAM tasks not allowed)

                                                                        51
Part-CAO (5/12)
                      Simple requirements
 → More privileges for the organisation to introduce changes
   → For activity on light aircraft, NDT and/or component other than
     complete turbine engine, the ‘scope of work’ can be changed
     in accordance with an approved procedure
   → Changes to location, facilities, tooling, equipment, material can
     be managed by the organisation
            Reduced involvement of Competent Authority
 → The possibility to work outside approved location is not
   limited to line maintenance
                                                                   52
Part-CAO (6/12)
             Airworthiness Review and ARC
 →More privileges to maintenance organisation for the AR
   (before limited to ELA1)

                                                       53
Part-CAO (7/12)
                      Permit to Fly
 →A CAO with AR/ARC privileges, may be additionally
  approved to issue a permit to fly
   → Limited to CAO registered in EU Member State
   → for those particular aircraft for which the CAO can issue the
     ARC

           Permit to fly is issued by the airworthiness review staff
                             authorised by the CAO

                                                                       54
Part-CAO (8/12)
                             Transition
  → CAMO, Part-145 or Subpart F Organisations will be issued a Part-
    CAO approval upon application
  → Current scope of work will be maintained by introducing
    limitations in CAO approval
  → Until 24 Sep 2021 to adapt the procedures and manuals to be
    compliant with Part-CAO
  → Limitations can be removed (if desired) only after complying with
    the corresponding elements and including the corresponding
    procedures in the CAE
                                                                   55
Part-CAO (9/12)
                        Transition (cont’d)
  → “Controlled environment” is not affected by the transition period
  → The organisation can benefit from the new Part-CAO
    alleviations/privileges only when the CAE is approved
  → Part-CAO approval will generate a new organisation Approval
    reference (update of EASA Form 1 and ARC)
  → Else, organisations use CAME/MOE/MOM until CAE is approved
    After CAE approval, maintenance organisations need CAM
   privilege to continue developing AMP

                                                                   56
Part-CAO (10/12)
       24 Sep 2019           24 March 2020                                           24 Sep 2021

                                      Request CAO
                                                                                                  CAO revoked if
                                            Issuance CAO                                        transition findings
                                                                                                   not closed !
Part-145 org.        Part-145 org.
                Surveillance i.a.w. Part-145 (existing scope of work)

                                                CAO approval (same privileges)
                                             Closure “transition finding” Part-CAO   Surveillance i.a.w. Part-CAO

                                                              CAE
                                                              approved
                Example: Transition from Part-145 to Part-CAO                                                         57
Part-CAO (11/12)
    24 Sep 2019              24 March 2020                                           24 Sep 2021

                                    Request CAO
                                                                                                CAO revoked if
                                        Issuance CAO                                          transition findings
                                                                                                 not closed !
Part-145 org.       Part-145 org.
     Surveillance i.a.w. Part-145                             Surveillance i.a.w. Part-CAO

                                             Closure “transition finding” Part-CAO

                                    Possible amendment to regulation!
                                                                                                                    58
Part-CAO (12/12)
 →Part-CAO not just created to replace Subpart F, but to
  offer a new type of organisation, adapted to GA, which
  can address all the needs of this community in the
  domain of continuing airworthiness
 →Part-CAO was developed with GA associations for
  GA community
 →EASA recommend all CAMO, Subpart F and Part-145
  organisation involved in GA to transition to CAO as soon
  as the regulation allows
                                                        59
Part-M (1/4)
 → Essentially amended to accommodate for the introduction of
   Part-ML, Part-CAO, Part-CAMO and BR reference:
  → Remove most GA alleviations
  → Certain requirement applicable to Part-CAO
 → Part-M subparts F and G: may still be used for 2 years; then
   approvals no longer valid
 → Opinion 13/2016 Technical Records (RMT.0276)
 → ‘Commercial DTO’ specifically mentioned

                                                                  60
Part-M (2/4)
 → Embodiment policy in M.A.301 is moved to Part-CAMO
   [CAMO.A.315(b)(4)]
 → Mass and Balance statement added in M.A.301
 → Possibility to amend aircraft technical log system by exposition
   amendment procedure
 → Clarification that the ARC cannot be issued until all findings have
   been closed

                                                                     61
Part-M (3/4)                    Transition
 → New structure of M.A.305, clearer on what continuing
   airworthiness records are and consistent record keeping period
 → “Service Life Limited Parts” (subject to a certified life limit or to a
   service life limit) replaced by “Life Limited Parts” and “Time-
   controlled Components”
 → “In-service history records” (used in ICAO) for life limited parts
   which partially incorporates the concept of “back to birth”
   traceability
  This rulemaking task also applies to the amendment of Part-145
                                                                         62
Part-M (4/4)              EASA Certificates
 → ARC: EASA Forms 15a and 15b amended
 → EASA Form 15c moved to Part-ML
 → AMO class ratings (Appendix IV) amended because no more ARC
   recommendation
 → EASA Form 3-MF (Subpart F approval) amended

          References to Basic Regulation (EU) 2018/1139
                                                                 63
Part-145 (1/2)
 → Essentially amended to accommodate for the introduction of
   Part-ML and BR
  → Airworthiness Review and ARC
      →Reference to Part-ML for the accomplishment method
      →Applicable to full scope of Part-ML aircraft (ELA1 today)
  → EASA Form 3-145 amended (issue 4)
  → Amendment privileges

      No privileges in developing AMP. AR for Part-ML aircraft
                                                                   64
Part-145 (2/2)
 → Essentially amended to accommodate for the introduction of
   Part-ML and BR
  → Airworthiness Review and ARC
      →Reference to Part-ML for the accomplishment method
      →Applicable to full scope of Part-ML aircraft (ELA1 today)
  → EASA Form 3-145 amended (issue 4)
  → Amendment privileges

      No privileges in developing AMP. AR for Part-ML aircraft
                                                                   65
Maintenance check flights (1/4)
 “Maintenance check flight” means a flight carried out to provide reassurance of
 the aircraft’s performance or to establish the correct functioning of a system or
 equipment that cannot be fully established during ground checks:
 → (a) as required by the aircraft maintenance manual (AMM) or any other
    maintenance data issued by a design approval holder being responsible for the
    continuing airworthiness of the aircraft; or
 → (b) after maintenance, as required by the operator or proposed by the
    continuing airworthiness management organisation; or
 → (c) as requested by the maintenance organisation for verification of a
    successful defect rectification; or
 → (d) to assist with fault isolation or troubleshooting.
                                                                                66
Maintenance check flights (2/4)
 → A maintenance check flight is a continuing airworthiness tasks (M.A.301)
   →   CAMO needs procedures
   →   CAMO needs to ensure adequate coordination between operator and maintenance
       organisation
 → The CAMO (in consultation with the maintenance organisation) needs to
   →   identify the need for a maintenance check flight; and
   →   decide if a PtF is required
 → The maintenance organisation may need input/data obtained during the MCF
   and/or finish the maintenance after the MCF. A certificate of release the
   maintenance is required then.

                                                                                67
Maintenance check flights (3/4)
→ A PtF is only needed when during the flight the airworthiness
  requirements cannot be met
→ Other maintenance check flights can be conducted under the CofA, without
  PtF, where
  →   the need of the maintenance check flight is part of the maintenance instructions
      produced by the design approval holder (within aircraft limitations). A release to
      service with incomplete maintenance should be issued before the maintenance
      check flight;
  →   the operator wants to conduct a maintenance check flight for reliability purposes
      (e.g. to assess adequate aircraft operation after have undergone complete heavy
      maintenance);
  →   confirmation (confidence gain) is necessary that maintenance (on ground) has fixed
      a system, that could not be verified on ground, despite maintenance instructions
      were followed.                                                                     68
Maintenance check flights (4/4)
                               Regulatory changes timeline
                                              Rule                          AMC/GM
                                Publication          Applicability   Publication/applicability
 Air Ops (EU 965/2012): Part
 NCO/SPO                     4 Sept 2019/5 Sept
                                                                      16 Sept 2019 / 17 Sept
 (EU 2019/1384 + EU                  2019         25 Sept 2019
                                                                               2019
 2019/1387)
 + ((EDD 2019/019/R))
 Initial Airworthiness (EU
                                                                       28 Aug 2019/29 Aug
 748/2012): Part-21
                                 03 Jun 2019      23 Mar 2020                 2019
 (EU 2019/897 +corrigendum)
 + ((EDD 2019/018/R))
 Continuing Airworthiness                     N/A                            1Q 2020
 (EU 1321/2014): Part M/145
                                                                                                 69
Mixed Operations (1/4)
 The same aircraft is used:
  Early morning:   by the AOC holder for a CAT flight
  Late morning:    by an SPO operator* for an aerial photography flight
                   *: It may be the same AOC holder, which is also a declared SPO
                   operator.

  Noon:            by another operator (Owner) for a private flight
                   (NCC/NCO)
  Afternoon:       by an ATO for a training flight
  Next morning:    by the same AOC holder for a CAT flight
                                                                                    70
Mixed Operations (2/4)
  Following a change of use of the aircraft from CAT
  operations to non-commercial operations or to
  specialised operations, the responsibility for the
  continuing airworthiness of aircraft subject to that change
  should be kept at the AOC holder level. Therefore
  Annexes I (Part-M) and Vb (Part-ML)

                                                           71
Mixed Operations (3/4)
  → Enable the use of aircraft included in an AOC by other
    operators, non-AOC holders;
  → Identify the aircraft used by other operators in the AOC
    holder’s documentation;
  → Require a procedure to identify which operator is responsible
    for operational control for each flight outside AOC;
  → Describe how the shift of operational control is communicated
    between operators.

                                                                72
Mixed Operations (4/4)
  The other operator’s responsibilities (NCC/NCO or SPO):
  →Comply with the applicable requirements;
  →Record every flight in the aircraft technical log system;
  →Contact the AOC holder for any technical issue of the a/c while under
   its operational control;
  →Report any occurrence to the AOC holder in due time and before next
   CAT flight.

  Continuing airworthiness remains with the AOC holder.

                                                                       73
Thank you

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