SOUTH ASIA REGIONAL INITIATIVE

Transcription

1 SOUTH ASIA REGIONAL INITIATIVE 7th SARI M WG meeting Prepared by: ED Kathmandu 26 to 28 February 2018 MEETING PARTICIPANTS CAA Nepal CAA Bangladesh CAA Bhutan CAA Maldives CAA Sri Lanka Yeti Airlines Air Dinasty Heli Services Buddha Air Air Dynasty Nepal Airlines Fish Tail Air Mountain Helicopter Regent Airways US Bangladesh Biman Bangladesh EASA SARI DGCA India and CAA Pakistan did not attend. Refer to the detailed list of participant given in annex 1. Meeting agenda is attached as annex 2. SUMMARY 1. Status of implementation of SARI Part M issue 1 by SARI Member States CAASL is implementing currently IS M based on SARI Part M issue 1. Full implementation will be completed in The first CAMO approval is expected in 06/18. CAAM has issued MCAR M, a regulation based on SARI Part M issue 1 plus some of the changes brought by issue 2. BCAA has adopted SARI Part M issue 1 but without the ARC provision. Instead Certificate of Maintenance Review is in place. 2 CMR are performed per year for each CofA. CAAB has adopted SARI Part M issue 1 and published the corresponding ANO. 4 CAMO SARI M WG 7th meeting Summary Final issue 1 / 9

2 (international airlines) approval process should be completed in May All airlines should have CAMO approved by July Adoption of Part M issue 2 will be considered when all issues with Part 1 have been fixed. CAAN has adopted SARI Part M issue operators have their CAMO approved and 5 other approvals are in progress. 2. SARI Member States comments on SARI Part M issue 2 and other remarks All comments from SARI MS have been answered in writing prior to the meeting with the exception of 3 comments from CAA Pakistan (PCAA). Concerning the remarks from PCAA it was agreed: Delete in M.A.100(h) as defined in CS23.1 & CS23.3 In M.A.201(i) to keep the sentence unchanged In sub-paragraph 2 of M.A.201(h) to correct the omission and come back to the EASA wording of the corresponding sub-paragraph In addition in M.A.100 Maintenance Organisations will be replaced with Continued airworthiness and Maintenance of Aircraft. 3. Summary of Part M amendments since publication of EC 2015/ 1536 & ED 2015/024/R and future regulation changes EASA explained that since 2013 the Agency has developed several draft regulations which have been through the EASA consultation process and the following opinions concerning Part M have been issued: 10/2013: EC regulation 1088 Part M for General Aviation Phase 1 12/2013: Control of suppliers (more details provided) 05/2015: B2L & L Part 66 maintenance licences (for glider, balloon and ELA2) 05/2016: Part M for General Aviation Phase II 02/2016: Embodiment of SMS 12/2016: Ageing Aircraft Structure 13/2016: Technical records However, with the exception of 10/2013, these draft regulation amendments are still awaiting approval of the EC but their technical content should not be significantly modified when they are finally published hopefully end of 2018 or in EASA in addition presented the tasks they are working on that may affect directly or indirectly Part M or other airworthiness related SARI Parts: Part M without Form 1 (Take into account criticality of the part) Refer to presentation on CAW update Helicopter Emergency Medical Services (HEMS) SMS Phase II (Part 145, POA and DOA) Complete review of Part 66 & 147 Certification Specification MCSD SARI M WG 7th meeting Summary Final issue 2 / 9

3 ACAM Key Risk elements Other tasks include B1 & B2 support task clarifications, import of aircraft, airworthiness review, new teaching & training techniques for Part 147 organisation and clarification on CAMO and MRO responsibilities. 4. Agreement of the SARI Member States on EU/EASA regulation adoption: After discussions and review of the content of the EASA opinions listed above the SARI MS agreed not to consider adoption of EU regulation 1088 regarding General Aviation as a priority and to focus during the meeting on other regulations such as opinion 06/2016 on SMS amending regulation EU regulation 1321/2014. It was also agreed to wait for the official publication of the regulation amendments covered by opinions 2016/05, 02/2016, 12/2016 & 13/2016 before further consideration for adoption by SARI. 5. Review of EASA opinion 06/2016: EASA explained that this opinion introduces safety management in continuing airworthiness management through the creation of a new Annex Part-CAMO to Commission Regulation (EU) No 1321/2014 concerning continuing airworthiness management organisations (CAMOs), which are managing aircraft operated by licensed air carriers and/or complex motor-powered aircraft. Through this amendment only Part-CAMO approved continuing airworthiness management organisations will be required to implement SMS. Because of this new Part- CAMO, Part M Subpart G is deleted. For other than complex motor-powered aircraft used for commercial specialised operations, or for CAT operations other than those performed by licensed air carriers the operator shall ensure that continuing airworthiness is covered by a Part CAMO or Part- CAO. There is no SMS requirement for Part-CAO but Quality System requirement. It was emphasized that SMS required by Part-CAMO follows ICAO annex 19 but encompassed SMS and Quality System. Part-CAMO AMC & GM have yet to be developed. The SARI MS had mixed opinions concerning the adoption of Part-CAMO when available: CAASL recommended to follow the SARI approached for Part 145 by adding a specific annex referring to ICAO annex 19. CAAM who has recently revised MCAR M suggested waiting for the official publication of the EASA Part-CAMO before making any change to SARI Part M. CAAB do not intend to change their Part M at issue one immediately as they wish to measure the progress of the operators before any change. However should EASA publish Part-CAMO in the coming months then the CAAB may skip adoption of SARI Part M issue 2 and wait for the publication of SARI Part M issue 3 including adoption of Part-CAMO. CAAN indicating they would prefer to stay for some time with the current SARI Part issue 2 before any change be made. However the SARI MS recognised that their priority was to be compliant with the ICAO SARI M WG 7th meeting Summary Final issue 3 / 9

4 annexes. Therefore adoption of SMS regulation as per SARI Part 145 was agreed. During the discussions few actions emerges: Check definition and consistency of the ELA1 (EASA) and LA1 (SARI) definitions Add LA2 definition for consistency with the content of Part 21 that now refers to LA2 Identify in SARI Part 145 issue 2 the reason why paragraph 145.A.48 in EASA Part 145 introduced by EC regulation 2015/1536 has not been adopted. 6. Question & Answer session The following questions were addressed: Working time in maintenance Guidance can be found in ICAO document 9824 CAMO.A Frequency of sub-contractor audits at least 1 per year Part-CAMO 305(d) regarding man hour plan for CAMO not existing currently in SARI Part M Subpart G issue 2 Release of maintenance performed to components removed from aircraft: Maintenance of components removed from aircraft shall be release on an EASA Form 1 by an adequate C rating organisation. In some particular cases maintenance on components can be done by A-rated organisation and released as part of aircraft maintenance, these cases are described in M.A.502. Applicability of Part ML (M Light): Part-ML applies to the following aircraft when they are not listed in the air operator certificate of an air carrier licensed in accordance with Regulation (EC) No 1008/2008 and not classified as complex motor-powered aircraft: (1) aeroplanes of kg maximum take-off mass (MTOM) or less; (2) rotorcraft of kg MTOM or less certified for a maximum of up to 4 occupants; and (3) other ELA2 aircraft; Unlimited validity of certificates Definition of compliance monitoring Form 4 for ARC staff The Form 4 are completed and signed by the person who is nominated in the Form 4 (applicant). Each nomination of a new ARC staff requires a CAME amendment (CAME 5.2 List of airworthiness review staff) Items excluded from requiring a maintenance release such as first aid kits, independent portable light, megaphone, etc..are listed in EASA Air OPS Part CAT.IDE.A instruments & equipment - general. 7. Ultralight Aircraft Operations in Nepal Besides the meeting the CAAN requested EASA and SARI to provide guidance to cover the airworthiness of Ultralight Aircraft when operated in CAT. The following suggestions were made: To provide them with an adapted framework for airworthiness addressing acceptance of the type certificate, continuing airworthiness, maintenance as well as maintenance personnel license. Team up with the existing operators to define a simplified system for continuing airworthiness and maintenance approval (including a simplified manual, responsible person for airworthiness, maintenance, approved maintenance schedule, etc) SARI M WG 7th meeting Summary Final issue 4 / 9

5 When the regulation is available to use PART CAO and not to go beyond. 8. Conclusions SARI Part M issue 2 will be amended through the SARI NPA process to include SMS in CAMO as previously done for Part 145 (refer to paragraph 5) and to correct errors and omissions as indicated in paragraph 2. The draft NPA will be distributed for comments to the SARI M WG members in 2018/Q2 and hopefully published at the latest beginning of 2018/Q3. ************* SARI M WG 7th meeting Summary Final issue 5 / 9

6 Annex 1 Country Participant Organisation Bangladesh Md. Shafiul Asam CAAB Bangladesh Dewan Rasheed Uddin CAAB Bangladesh Wasique Alam US Bangla Airlines Bangladesh Md Ghulam Sarwar Ali Ansari Biman Bangladesh Airlines Bangladesh Ganesan Samuel Regent Airways Bhutan Sangay Tenzin BCAA Bhutan Namgyel BCAA Maldives Mr. Abdulla Mohammed CAAM Nepal Besh Raj Subedi CAAN Nepal Bidhan Shrestha CAAN Nepal Bharat Raj Parajuli CAAN Nepal Hem Kumar Dahal CAAN Nepal Jose Salguiero CAAN Nepal N.D. Pant Yeti Airlines Nepal Shanad Ky Wagley Yeti Airlines Nepal U.B. Shrestha Air Dinasty Heli Nepal Bikram K.C. Nepal Airlines SARI M WG 7th meeting Summary Final issue 6 / 9

7 Nepal Prabhash Kumar Karmacharya Nepal Airlines Nepal U.L. Shrestha Buddha Air Nepal M.K. Shrestha Fishtail Air Sri Lanka Padmi Jayawardhana CAASL Europe Rosa Tajes EASA Europe Eric Dormoy SARI SARI M WG 7th meeting Summary Final issue 7 / 9

8 Annex 2 SARI M WORKING GROUP SEVENTH MEETING Kathmandu 26 to 28 February 2018 DAY Opening (CAAN/SARI) Introduction of the participants Draft agenda approval (SARI) Status of implementation of SARI Part M Issue 2 dated 31 July 2017 by the SARI CAAs (SARI CAAs) SARI MS comments on Part M issue 2 (PCAA/CAAB) (EASA) Coffee break Main SARI MS issues and how to overcome these issues Lunch Summary of EASA Part M amendments since EC 2015/ 1536 & ED 2015/024/R (EASA) Tea break Agreement on the regulation changes (EC Reg / EASA ED to be adopted by SARI Part M) Wrap-up day 1 (SARI) SARI M WG 7th meeting Summary Final issue 8 / 9

9 DAY Detailed review of the latest EC regulations and ED amendments to be considered by SARI Part M Coffee break Detailed review of the latest EC regulations and ED amendments adopted by SARI Part M (Cont d) Lunch Detailed review of the latest EC regulations and ED amendments adopted by SARI Part M (Cont d) Tea break Detailed review of the latest EC regulations and ED amendments adopted by SARI Part M (Cont d) Wrap-up day 2 DAY Issue of Part M and ultralight aircraft in Nepal (CAAN) Coffee break Presentation of opinion NPA (EASA) Way forward for ultralight under Part M in Nepal (CAAN) Lunch Question and answer session on Part M Tea break Wrap-up and conclusions (EASA/SARI) ********** Day 1 to 3: Starting 9.am Closing 4.30 The agenda was amended in order to address ultra light aircraft operations in day 2 from 3 pm SARI M WG 7th meeting Summary Final issue 9 / 9