EASA Production and Maintenance Workshop. Location: Hotel Cologne, Rudolfplatz

Transcription

1 EASA Production and Maintenance Workshop Date: 9 th September 2015 Location: Hotel Cologne, Rudolfplatz The intention of the first EASA Maintenance & Production workshop (M&P) was to facilitate discussion with affected stakeholders and national authorities on a variety of technical matters (See attached agenda). The meeting attracted 177 delegates not only from within Europe but worldwide. After an initial welcome from Julian Hall (Head of M&P), we were introduced to Mr Ricardo Genova Galvan the new Director of Flight Standards (FS) at EASA. Julian followed this by providing an update on changes within the FS Directorate, highlighting the 5 units of which for EIMG interest FS1=M&P headed by himself and FS1.2 headed by Juan Anton Maintenance Regulations Section Manager. (1)-Update on existing Bilateral Agreements and implementation issues, including planned TIP update for reciprocal acceptance of ETSOA/TSOA EASA explained their current and pending Bilateral Arrangements Existing with USA and Canada- currently working with TCCA for increased mutual benefits. Brazil Bilateral BASA on Maintenance (MAG) signed 11 June 2015, Workshop planned for October 2015 Potential new Bilaterals with China and Japan- China to focus on Certification and Production Japan to focus on Production, although would consider maintenance upon request from EU industry. EU BASAs will add a third Annex (Pilot Licensing) to their existing structure. Annex 1 already covering Design/Certification and Annex 2 already covering Maintenance (Aircraft & Components). At the last Joint Maintenance Co-ordination Board (JMCB) held in Brussels 12 June 2015 the approval of MAG Change 5 was discussed. Sampling Inspection System (SIS) Visits- FAA performed SIS visits to 3 EU Member State NAAs those being Italy, Germany and the UK, EASA program almost complete which includes SIS visits to 6 US FSDOs With regard to the EU/USA Bilateral, Rev 5 of the TIP is expected to be signed 14 th September during the Certification Oversight Board (COB), and will be effective as of that date.. This will allow full cross acceptance of FAA TSO or EASA ETSO (with one or two exceptions e.g. APUs). So a part marked only with the FAA TSO will be acceptable in the EU and vice versa. (Parts will no longer need to be marked with an ETSO for EU aircraft installation). This will not exclude the need for the installer to ensure all the necessary EU requirements for installation are in place prior to installation.

2 (2)-Update on Acceptance of Foreign Production Production Organisation Approval (POA) EU 748/2012 Article 9.2 allows for the acceptance of foreign production organisations (without Part 21 subpart G approval). EASA Decision Paper 2015/023/E has been published to describe this activity. It would mainly relate to products (aircraft) manufactured in Australia and New Zealand. This would be conditional on: a. EASA would need to assess each NAA (this is currently in process for both Australia and New Zealand) b. The aircraft type being on at least one EU register c. The aircraft type being accepted/identified as part of the EASA assessment d. Etc. (3)- Global Recognition of Maintenance Organizations Mutual Recognition AMO The activities performed at ICAO level in the Airworthiness Panel is a good way forward in promoting the mutual recognition of maintenance organisations. It was generally agreed that the objective is not just to reduce the number of audits but to better focus the efforts. Other Detail Transfer of AMO requirements from ICAO Annex 6 to 8 in order to emphasize concept of stand-alone AMOs not directly linked to Operators. Change term maintenance records to Continuing airworthiness records Align definition and statements related to the release of maintenance. Provide additional guidance in the Airworthiness Manual (doc 9760) with respect to a) Approval process of the AMO b) Rating system for AMO c) Acceptance of the approval by other states Proposals arising from the high level safety conference 2015 a) recommend development of global framework and regional initiatives to reduce duplication of certification and surveillance activities of AMOs b) To achieve this goal (i) amend ICAO standards (provide guidance) in order to incorporate more specific requirement (ii) continue promoting regional activities to create common standards at regional level (iii) complemented by use of industry standards for audits and (iv) reliance on pooling of audits. (4)- Fraud in Part-147 Basic Examinations and possible Regulatory Measures Part 66/147 Fraud cases, a disturbing issue has arisen whereby some MTO s are committing fraud in order to facilitate people to pass the basic exams and gain a Part 66 license. EASA are to introduce some emergency measures to mitigate this occurring in the future. These will be announced very shortly. Background Info-Annex III (Part-66) to Regulation (EU) No 1321/2014 allows that basic knowledge examinations for certifying staff can be conducted either by an approved Part-147 maintenance training organisation or by the competent authority.

3 In the case of Part-147 organisations, the examination can be performed either in conjunction with the basic training course they impart or as a stand-alone examination. Description of Problem No concern in relation to the examinations performed by Part-147 organisations when they are part of a basic training course (typically lasting 2 or 3 years). However, a significant number of fraud cases have been reported of Part-147 organisations providing: unofficial training as short as a few days long, where they provide information on the upcoming content of the examination, and guarantee that they will pass the examination These practices take place in and outside Europe, mainly away from the base location of the Part- 147 organisation, where oversight by the competent authority is more difficult or not possible to plan. This is a major safety concern, with the risk of having the aviation system flooded with licence holders not having the required basic knowledge. Expected Measures Due to this immediate safety concern, during the summer of 2015 the Commission agreed on an expedited procedure which would result on the Agency issuing an Opinion to be presented in the EASA Committee of 14/15 October In order to ensure that the applicable consultation obligations contained in Regulation (EC) No 216/2008 are met the following has been performed: Stakeholders and NAAs were informed of the Part-147 fraud concerns and on possible measures to be taken at the following events: Engineering & Maintenance Sub-SSCC on 02 June Standardisation Meeting with the NAAs on 02/03 June 2015 Stakeholders and NAAs are being informed on the exact changes to be included in the Opinion at the following events: Production & Maintenance TAG meeting on 08 September 2015 Maintenance & Production Conference on 09 September 2015 Proposed Changes to the Rule 147.A.145 Privileges of the maintenance training organisation (a) The maintenance training organisation may carry out the following as permitted by and in accordance with the maintenance training organisation exposition: 1. basic training courses to the Annex III (Part-66) syllabus, or part thereof. 2. aircraft type/task training courses in accordance with Annex III (Part-66). 3. the examinations on behalf of the competent authority, including the examination of students who did not attended the basic or aircraft type training course at the maintenance training organisation. 4. the examination of students who did not attend the aircraft type training course at the maintenance training organisation. 5. the examination of students who did not attend the basic training course at the maintenance training organisation, provided that: the examination is provided at one of the locations identified in the approval certificate, or if performed at other locations as permitted by points (b) and (c), either the competent authority selects the questions and supervises the examination or

4 the examination is provided through a European Central Question Bank 4 6. the issue of certificates in accordance with Appendix III following successful completion of the approved basic or aircraft type training courses and examinations specified in points (a)(1), (a)(2), and (a)(3), (a)(4) and (a)(5), as applicable. Expected Impacts POSITIVE: Addresses the immediate safety concern. Should eliminate the unfair competition created by those organisations which are performing basic examinations not meeting the standards and which are attracting customers with a guaranteed examination success. Should prevent future cases of unfair competition created by individuals who obtain a Part- 66 not meeting the adequate standards. These individuals are lowering the employment opportunities of those Part-66 licence holders who obtained the Part-66 licence in a fair manner. This limitation will likely accelerate the creation of the European Central Question Bank (ECQB), which is the long-term solution to the problem. This ECQB would also be beneficial from an economic point of view for the Part-147 organisations and competent authorities since they would not need to create, maintain and oversee the questions for the examinations. NEGATIVE: Affects Part-147 organisations providing examinations (without a course) at locations not listed in their approval certificate, if they cannot get an agreement with their competent authority to select the questions and supervise the examination. Impact could be minimized by having the maximum number of training facilities included in the approval certificate, once the authority has performed the corresponding audits In such a case, the locations which will be typically affected by the limitation will be those places where the organisation is performing examinations based on an approved procedure, without the location being identified in advance. Possible impact on NAAs due to limited resources (if they cannot change the fee charging system) (5)-Developments in the MRB Process Two initiatives for improvement (i) Introduction into the BASA and (ii) Use of TC holders (DOAs) (i) Current Issues- Significant Duplication of efforts as multiple authorities are directly involved in each aircrafts MRB process. Future- Working towards accepting trusted partners approval (ie) EU/US TIP Amendment 6 expected around April 2016 (ii) DOA progress from MRB IE (Indistry/EASA) Concept agreed between EASA/ASD List of routine envelope agreed 4 TC Holders have submitted applications and procedures, all of which are at various stages of investigation. (Dassault, Airbus, Agusta Westland and Airbus Helicopters) Pilot cases to be run/in progress.

5 (6)-Developments in GA (B2L + L Licences, Light Part-M, CS-STAN) CS-STAN has been published via decision 2015/016/Rand 9 July This specification provides standards that owners of LA2 aircraft (and below) can use, without further showing, for minor repairs and changes (mods). It for example recognises FAA AC43-13b for minor repair data. It also lists in appendix format various acceptable modifications that can be installed providing the owner/maintenance organisation declare that the change was accomplished fully in compliance with the applicable CS-STAN appendix. Part M Light (Part ML) is now subject to NPA (published 9 th July 2015) and is still open for CRD comment until October. This will introduce a lot of alleviations for the small recreational aircraft community. Right down to a mechanic being able to renew ARCs (LA1 aircraft non-commercial) B2L & L licences proposed in opinion 05/2015 on 22 June It was presented to the EC and member states in the EASA committee July 2015 and will be discussed further in the next meeting planned October 2015 Rule expected to be adopted by commission second half of 2016 Presentation received from Greg Bowles (GAMA), with additional input from Werner Scholtz (ESM) (7)- Quality Systems and SMS SMS, a lot of concerns were expressed from the audience about the introduction of SMS. EASA have decided to break the implementation of SMS down in to two phases: Phase 1 introduce SMS in to EASA Part M for CAMOs OPINION EXPECTED EARLY 2016 Phase 2 introduce SMS in to 145, POA and DOA NEW NPA TO BE ISSUED IN 2017, this will also assess the need for changes in Subpart F AMOs and Part-147 organizations. Presentations on subject matter also received from; Simon Roberts (CAA SMS Program Lead), Gilles Garrouste (Dassault/ASD/EAB Chair), Werner Scholtz (European Sailplane Manufacturers) and Karl Specht (Continuing Airwothiness Organizations Manager EASA) (8) New Business Models (Contracting of CAMO services, Interoperability arrangements) Rules should not prevent business evolution and effoiciency However rules should prevent, dilution of responsibilities/liabilities, flags of convenience and business/financial engineering detrimental to aviation safety. Note A side meeting was held by EASO member Tony Heather with Juan Anton (CAW Manager EASA) and he confirmed that NPA (which will include Supplier Oversight and the recognition of EASO 2012 as an acceptable standard for Suppliers) is to be presented to the EASA EU Committee in Brussels October All things being equal due process (comotology) will then follow and the rule should be published circa 3 rd quarter 2016.

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