SOUTH ASIA REGIONAL INITIATIVE

Transcription

1 SOUTH ASIA REGIONAL INITIATIVE 7th SARI 66 & 147 WG meeting Prepared by: ED Colombo from 25 to 27 February 2015 MEETING PARTICIPANTS CAA Sri Lanka CAA Pakistan Biman Bangladesh EASA SARI Refer to the list of participant given in annex 1 SUMMARY The draft agenda was approved without further modification and is given in annex The status of national regulations on maintenance personnel licensing is as follows: - Bangladesh: According to Biman Bangladesh ANO 147 & 66 have been published including amendment Regarding 147, any new application should be against the ANO 147. Biman Bangladesh has been audited by CAAB and their Part 147 approval is expected during 2015/Q2. Biman Bangladesh could not comment about the status of the previous CAAB maintenance personnel licencing but stressed that the conversion process of the licences from the old to the new system has not started yet. SARI will contact the CAAB to get further information. (Action: SARI Coordinator). - Pakistan: ANO 147 & 66 have been issued and are implemented. PIA Training Center Part 147 approval has been granted. This approval covers basic course as well as type training. 2 other organisations have also been approved. Regarding compliance with Part 66 a conversion matrix has been published and 700 out of 5000 licences have been converted. Bhutan: Will adopt SARI Part 66 and SARI Part 147 when available. - Sri Lanka: The current ASN still refers to the EASA Part 66 and 147 regulations adapted by CAA SL in As the latest EU / EASA Part 66 and 147 amendments have not been taken into account the current ASN includes a significant number of National Variants. These variants are progressively removed to be aligned with SARI Part 66 & 147. All licences are now issued according to Part training organisations SARI 66 & 147 WG-7th meeting Summary Final issue 1 / 11

2 hold a Part 147 approval. CAA SL however has yet to publish procedures in compliance with Section B. - Maldives: MCAR 66 & 147 fully matching EASA Part 66 and Part 147 have been adopted and implemented but without Section B. Section B will be published when the final draft of SARI Part 66 and 147 is be available*. Bhutan India, Nepal and Maldives who did not attend the meeting will be required to confirm the status of implementation with SARI Part 66 & 147 (Action ED). SARI regretted the slow progress made regarding the implementation of SARI part 66 and 147 as well as the move from some Member States to adopt recent EU/EASA Part 66 & 147 amendments not included yet in SARI Part 66 and Part 147. However as SARI has not been able to arrange any SARI 66 & 147 WG meeting since September 2012 it reckoned that SARI bears the responsibility of the disparity that has been created between the SARI member States. 2. Review of the latest EASA Part 147 Amendments: The current SARI Part 147 is the initial issue dated 15 February 2013 based on Regulation 707/2006; 376/2007; 1056/2008; 127/2010 & 962/2010 and EASA ED Decision 2006/001/R and elements of 2010/002/R. The meeting objective was to review the impact of EC Regulation 1149/2011 on SARI Part 147 and to agree on possible changes that will be process through the SARI NPA process. The meeting did not review EASA ED Decision R nor It was however stressed during the meeting that B has no impact on Part 147. The following changes were agreed: 147.A.125 Unlimited period as per 1149/2011-It was emphasised that nothing in the rule ask for hard or soft copy and in any case nothing should be lost. 147.A.145(i) (e) Change wording according to 1149/2011 An organisation may not be approved to conduct examination unless Approved to conduct the corresponding training. 147.A.145(ii) (f) added according to 1149/2011 Title Subpart C changed to Approved Basic Training Course 147.A.200(b) Wording change according to 1149/2011 Title for Section B changed to Procedures for Competent Authorities 147.B.15 is kept as it is (1149/2011 delete the paragraph) 147.B.120(a) is replaced by the new paragraph introduced by 1149/2011 The objective is to do the oversight of the organisation and ensure the trainers can deliver. Replace Appendix I in accordance with 1149/2011 Amend Appendix II in accordance with 1149/2011 Replace Appendix III in accordance with 1149/2011 (NV for SL Does not delegate the examination). These changes will be included in a NPA to be distributed to the SARI Member States for agreement or comment before the 31 st of March (SARI Coordinator). SARI 66 & 147 WG-7th meeting Summary Final issue 2 / 11

3 3. Review of latest EASA Part 66 amendments: All the changes brought by 1149/2011 were agreed with the following exceptions: 66.A.40(b) Not relevant for SARI 66.A.70 Agreed but all MS to check their definition of Commercial Air Transport. The definition of CAT in SARI Part M should be the definition accepted by all the MS 66.B.10(a) Retain the current SARI Part 66.B.10 wording 66.B.15 Retain SARI Part 66.B.15 wording 66.B.120 Agreed except for CAA SL (NV) 66.B.125(a) Agreed but delete referred to in point 4 of article 5 66.B.200(i) Agreed but add or in accordance with the applicable National Regulations 66.B.300 Retain the current SARI Part 66.B.300 wording 66.B.310 Retain the current SARI Part 66.B.310 wording 66.B.405 Remove examination in the title The complete review of 1149/2011 was not completed during the meeting 4. Open Question and Answer session The main questions addressed during the Q&A session are recorded in Annex Next SARI Part 66 Implementation workshops 2 Implementation Workshops are planned in 2015 in Sri Lanka and in Pakistan. The dates of this workshops will be agreed before 2015/Q2. 6. Conclusions: As the complete review of the potential impact of 1149/2011 was not completed during the 7 th SARI 66 & 147 meeting, the 8 th meeting will be held during of 2015/Q4 to complete the task as well as to review ED R and ED R. The NPA proposing the changes to SARI Part 66 Issue 1 dated 15 December 2012 based in the inputs of ED R and ED R will be published before the end of The NPA proposing the changes to SARI Part 147 Issue 1 dated 15 February 2013 based on 1149/2011 will be circulated to the SARI Member States end of March ************* SARI 66 & 147 WG-7th meeting Summary Final issue 3 / 11

4 Annex 1 Country Participant Organisation / Title Bangladesh Mr. ABN Nozmul Huda Biman Bangladesh Mr. Md. Ali Naser Biman Bangladesh Mr. Iqbal Hossain Biman Pakistan Engr. Ahmad Masood Mahfooz Pakistan CAA Sri Lanka Mr. Susantha De Silva CAA Sri Lanka Sri Lanka Mr. E.P.B Liyanage CAA Sri Lanka Sri Lanka Ms. Champika Vidanapathirana CAA Sri Lanka Sri Lanka Mr. Ranjith Perera CAA Sri Lanka Sri Lanka Mr. Chaminda Wimalratne CAA Sri Lanka Sri Lanka Mrs. Malka Pathirana CAA Sri Lanka Sri Lanka Ms. Padmi Jayarwadena CAA Sri Lanka Sri Lanka Mr. Terrence Senanayake CAA Sri Lanka Sri Lanka Mr. Nelson Rubasinghe CAA Sri Lanka Sri Lanka Mr. Sandaruwan Abeysinghe CAA Sri Lanka Sri Lanka Mr. Gimhan Dabarera CAA Sri Lanka Sri Lanka Mr. Harsha Priyadarshan Sri Lankan Airlines SARI 66 & 147 WG-7th meeting Summary Final issue 4 / 11

5 Sri Lanka Mr. Samitha Ranasinghe Sri Lankan Airlines Sri Lanka Mr. Amila Fernando Sri Lankan Airlines Sri Lanka Mr. Gallella M.M.A.B. Sri Lankan Airlines Sri Lanka Mr. Ranga S. Peiris CINEC Technical Training School Sri Lanka Mr. Mahinda Abeysinghe Skyline Aviation Engineering Academy Sri Lanka Wg Cdr. BJK Lokupathirage Kothalawala Defense University Sri Lanka Mr. Sarada Mawitagama AAC Engineering Academy Sri Lanka Gp. Capt. Ranjith Senanayake Helitours Technical Training Center Europe Mr. Eric Mills CAAi/EASA Europe Eric Dormoy SARI SARI 66 & 147 WG-7th meeting Summary Final issue 5 / 11

6 SARI 66 & 147 WG-7th meeting Summary Final issue 6 / 11

7 Annex 2 SARI 66 & 147 WORKING GROUP 7TH MEETING Colombo 25 to 27 February 2015 Draft Agenda DAY 1 (SARI Part 147) -Introduction -Reminder on SARI Part 147 published on -Status of adoption and implementation of SARI Part 147 by SARI Member States -Status of EASA Part 147 (latest EC regulation and EASA EDD published by EASA) -Review of the EASA Part 147 amendments released till end of 2014 for possible integration into SARI Part Wrap-up day 1 DAY 2 (SARI Part 66) -Reminder on SARI Part 66 published on - Status of adoption and implementation if SARI Part 66 by SARI Member States - Status of National Variants adopted by SARI Member States - Status of EASA Part 66 (latest EC regulation and EASA EDD published by EASA) - SARI Part 66 references - Review of the EASA Part 66 amendments released till end of 2014 for possible integration into SARI Part 66 - Wrap-up day 2 DAY 3 (Open Q&A session on Part 66 & Part 147) -Specific issues to be discussed with the Technical Advisor (the WG members are required to provide a list of topics they wish to be addressed) -Wrap-up ******** The meeting will start every day at 9 am and will finish no later than 5 pm Coffee break: from a.m. to 11 a.m. Lunch break: from a.m. to 1.30 p.m. Tea break: from 3 p.m. to 3.30 p.m. SARI 66 & 147 WG-7th meeting Summary Final issue 7 / 11

8 Annex 3 Questions and Answers session Sri Lanka February ) What qualifications are required for authorisation of Instructors, Examiners and Assessors in 147 Approved Training Organisations? Answer: The procedures used to qualify and authorise any instructor, examiner or assessor are laid down in Section 3 of the Approved Training Organisations MTOE. This section should contain the pre-qualifications required respective to the subjects to be covered. An examiner need not have any technical knowledge providing that he/she knows how the examination system operates and the questions are written and validated by technical experts. The approved organisations quality system should also have oversight of the whole process of question writing/validating/examination compilation and conduct of the examination. For type training the instructor must have had as a minimum a full level III type training course and have completed some hands on practical experience on the aircraft type. These qualifications should be supported by update training every two years. An assessor should hold a nationally approved assessors qualification. 2) Should an instructor be an aircraft maintenance engineer? Answer: It would be an advantage but it is NOT a requirement. What is important here is that the instructor is capable of delivering training in a manner that creates a good learning environment and he/she is technically competent to deliver that subject area. 3) How is an assessor for OJT in a 145 Approved Maintenance Organisation qualified and authorised? Answer: In exactly the same way as in a 147 Approved organisation except under the procedure laid down in the 145 MOE. 4) What standards are recognised for examiners and assessors? Answer: The requirements for the examiner will vary dependent on the type of examination system used. If the examination is paper based and marked by the examiner then he/she will need to be qualified to a similar standard to the instructor. If however the examination system is a fully automated computer controlled system then the examiner will only need to know how the examination system operates. For anything in between the qualifications required will vary also. 5) What facilities and equipment is required for approval of a basic training organisation? Answer: Could write a book here. From the outset buildings required are offices for administration, research and training development, production facilities, Quality Assurance etc..;classrooms and examinations rooms; Some training organisations have laboratories which combine theory and practical especially for electrics and electronics, toilets, restrooms, dining facilities or cafes, a library and a hangar. For equipment (assuming B1 & B2), an aircraft representative for the licence category. (Don t forget propeller for B1.1; A pressurised turboprop is best.) The aircraft should be capable of being ground run and handled for towing, steering, jacking etc but does not need to be a complete machine providing the majority of the systems are operable. If an ex-military machine is used this will need to be supported by civil equipment where there is a difference. Example parts such as landing gear, hydraulic components, air-conditioning components, electrical items and for Category B2 examples of all avionic equipment. Machinery for sheet metal work, fabrication of composite materials (including an autoclave). An area or room where wiring and looming can be practiced and test circuits for understanding electrical circuitry. A functioning or pseudo functioning autopilot is SARI 66 & 147 WG-7th meeting Summary Final issue 8 / 11

9 required for Cat B2 and this is usually part of a full flight control panel which can also be used for instrumentation for both B1 and B2 categories. If there are any other specific questions I will answer them individually. 6) What are the regulatory requirements covering the number of questions needed for a basic examination question bank? Answer: Detailed in 66 appendix II. 7) How is competency of an instructor maintained and who conducts any assessments? See question 1. 8) How many hours should be allowed for instructor preparation of training material? Answer: This will not only depend on the subject but also on the type of training material that will be used for the delivery of the training. For Module 1 it may only take around three/four days to prepare one day of training but for other areas where there is both theory and practical training to be considered it may take three to four weeks to prepare one day of training. It is also imperative that the equipment that is available and is capable of functioning as required for the training and training materials and schedules should be designed accordingly. 9) What areas of experience would be expected to be undertaken for an individual qualifying for a Category C licence using the graduate route? Answer: What should be remembered here is the function of the Category C base maintenance certifier once he/she is in place. The period of hands on with an aircraft is to expose them to the issues that the maintenance staff cope with on a day to day basis such as working in teams that have to be aware of what other teams are doing in order that they do not expose themselves to dangerous situations and also some of the vagaries of aircraft maintenance. But also the Cat C certifier must have a firm grasp of the functions within the records department, maintenance planning, stores, design (where an in house approval is held for modifications) workshops and other ancillary areas of the maintenance organisation. If work is conducted for third party organisations it would be prudent to introduce the Cat C certifier to these organisations to ensure that he is aware if any aircraft difference. 10) How is a degree qualification accredited to permit issued of a 66 category C licence? Answer: In accordance with 66.B.400 and 66.B.405. BUT, be very cautious here, even if the questions are the same as required in 66 what is the pass mark for the degree course? Even courses classed as aerospace are often aimed at the design engineer with a heavy mathematical input and systems such as FEA and systems failure but with little regard for maintenance and the structures regulating maintenance. It is appreciated that a degree is perceived as the ultimate qualification is the Asian culture but it must be remembered that a degree is fundamentally a knowledge based qualification whereas maintenance is a practical subject area. I personally have a BSc (Hons) in design and systems failure, but would not expect that to provide much credit towards a 66 maintenance licence. SARI 66 & 147 WG-7th meeting Summary Final issue 9 / 11

10 11) Is it permissible and what are the procedures for using OJT in lieu of practical training to meet the type training requirements? Answer: The principal difference between practical training and OJT is that the former is structured with dedicated instructors and examiners while the latter (OJT) is not instructor led and does not usually follow a planned syllabus. If OJT is planned and overseen by a competent licensed maintenance engineer and an examination process is conducted to a prescribed standard, then this OJT fundamentally meets the requirements of practical training. The disadvantage with this arrangement is that the OJT will need to be approved by the competent authority which means that other authorities are not bound to accept the OJT as meeting the requirements for licence issue. If there is no practical training available, and the type training is for extending a nationally issued licence, then it is within the remit of the national authority to approve such qualification. However the national authority must have a procedure and process in place along with appropriate records to show how the requirements for type training have been met. 12) Can military aircraft acceptable for use in basic training? Answer: Yes BUT. Military aircraft are suitable for practical training on items such as basic hydraulics, pneumatics (be careful with this description), structure, flight controls, jacking and trestling, the basic procedures for ground running etc. However pressurised structures, civil electronic systems, large undercarriages and high ratio bypass engines, large aircraft pressurisation and control etc will need to be included. If a military aircraft which may also be used in the civil environment such as a C130 is used, the differences may be limited to cockpit configuration, communication and navigation systems used and the use of military standard parts as opposed to parts that meet civil certification standards. 13) Can operational workshops and other such facilities be used for basic training? Answer: The activities in operational workshops are strictly controlled under the exposition for that organisation. (Note that I have NOT used the term 145 approved ). The reason for this is that at present component maintenance is undertaken in accordance with national regulation which may or may not require an organisation to be approved in accordance with 145. In any event it is unlikely that, the procedures for use in the workshop where maintenance of the component leads to the issue of an EASA Form 1 or equivalent, would permit unqualified staff or inappropriate spare parts to be present. It should be remembered that component workshops are usually strictly controlled clean areas and must remain so to ensure the likely hood of contamination is kept at a minimum. It may be possible to permit training in areas such as sheet metal workshops but there would need to be a strictly control segregated area for the training with no possibility of transference of materials from the training to the operational section. It would be safer to say that workshops cannot be used for training at all but it is understood that commercial pressure may force the issue. For the authority surveyor it is important to ensure that prescriptive measures are in place to ensure safety. 14) Can a 145 quality system add limitations to a 66 licence or authorisation? Answer: The 145 organisation cannot add limitations to a licence but can however limit the extent of the authorisation to reflect the competence of the individual. In fact in most cases the authorisation will limit certification of maintenance to the aircraft type concerned although the licence may permit a wider scope covering several aircraft types. For example the type rating for the B /700/800/900 (GE CFM 56) covers four aircraft types but the 145 organisation may only maintain the B (GE CFM 56) so any authorisation would be limited to this single type. This would be necessary to allow for two yearly continuation training to take place. 15) Can the examination of a type training level 3 include level 1 and level 2 questions as well? Answer: Basically yes. This is where there is a difference between basic and type training regarding the levels examination questions that should be delivered. In basic examination they SARI 66 & 147 WG-7th meeting Summary Final issue 10 / 11

11 are detailed in Annex II to be specifically either LOD 1, LOD 2 or LOD 3 but in type training the definition of level three training includes training at level 1 and 2 where the system is new to that aircraft type. It therefore follows that level 1 and 2 questions may be included in type training examinations. There are also areas which are important for safety reasons where a level 1 or 2 question would be appropriate. *********** SARI 66 & 147 WG-7th meeting Summary Final issue 11 / 11