Welcome! Bart Mak Owner and Principal Consultant at Mak Aircraft Engineering Services.
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1 Bart Mak Owner and Principal Consultant at Mak Aircraft Engineering Services Welcome! 1
2 Personal Background Career start as helicopter mechanic apprentice Bristow Helicopters KLM M & E, Engineer Aircraft Structures Martinair Fleet Management Aviation Technical Consultancy since
3 Company background Support of the leasing industry Audits (Pre-purchase, pre-return, mid-term) Handbacks Ex / import and registration Support of airlines Technical post-holder Tech rep AOG s / heavy checks Modification specs Handbacks, purchase New aircraft build and acceptance 3
4 Aircraft transitions Factory delivery Import / Export Purchase \ sale (Dry) Lease-in Lease handback AOC transition System transition / migration End of life part out 4
5 Considerations Airworthiness of the aircraft at transition (first and foremost) Binding regulations with CAA (EASA / FAA) Contractual obligations (Lease) Importing CAA requirements System data migration protocols AMP transitions (bridging) 5
6 Initial Airworthiness Compliance to type design In a condition fit to fly 6
7 Compliance to type design Verification means review of aircraft records and the current TCDS Modification records STC records, engineering data and supplemental manuals (ICAW, AFM, etc) Review of records as stipulated in EASA Part M M.A. 305 and EU-OPS subpart K & L for commercial aircraft >19 seats JAR-26 Subpart B compliance for commercial operation 7
8 Condition fit to fly Requires aircraft physical inspection (damages, repairs, deferred defects) Conformance with configuration records Presentation of latest CRS and maintenance history Presentation of storage records for inactive periods Has the aircraft been operated within utilization limits of the AMP? 8
9 What says M.A. 305? (a) Maintenance History (b) Log Books Airframe, Power plants and Props (or equivalent records) (c) Flight time logs or summaries (d) AD status Modification status Repair status AMP status Life Limit status Mass & Balance report Deferred Maintenance (e) (serialized) Component information 9
10 Part M M.A.305 par (h) is more specific All detailed maintenance records or until superseded by subsequent tasks (36 months) Total time in service of the aircraft and it time controlled components Time in service since last component scheduled maintenance until superseded Current status of an AMP Current AD status of airframe and components Details of current modifications 10
11 FAA rules for continuing airworthiness records and certification FAR Part 26 Continued Airworthiness and safety improvement for transport cat airplanes (intended for TC holders) FAR Part 121 (domestic or flag carriers) Subpart J, Special Airworthiness Requirements Subpart K, Instruments and equipment requirements Subpart L, Maintenance and reliability Subpart AA Airworthiness and safety improvement Maintenance records and transfer (!) Interior Flammability FAR Part 125 (commercial operators >20 seats > 6000Lbs payload) Subpart E, Special Airworthiness requirements Subpart F, Instrument and Equipment requiements Subpart G, Maintenance Part 43 Subpart M, Airworthiness and safety improvements Fuel Tank Flammability DFDR parameter requirements Repair assessment requirements 11
12 FAA regulations cont d FAR Part 135 Commuter and on-demand operations SFAR 36 (cancelled in 2009) Major repairs developed and approved under the provisions of this section 12
13 FAA guidance material AC 21-2L Import requirements from US AC 21-23B Importing requirement into US AC Maintenance and Alteration data AC Acceptance of Electronic Data AC Aging Aircraft Safety Assessment AC Damage Tolerance Inspections for Repairs and Alterations AC Instructions for fuel tank safety in CAW programs 13
14 ICAO Annexes and documents ICAO documents are basis for regulation but not regulation by themselves Annex 06 Operation of Aircraft, Chapter 8 Aeroplane Maintenance Annex 08 Airworthiness Doc 9760 Airworthiness Manual 14
15 What Part M and FAR don t say? Factory delivery documentation How to organize and present records (dirty finger prints, engineering data, certification material, back to birth trace material) Statements (accident incident history, EU-OPS subpart K & L compliance, RNP values, ETOPS, RVSM, PMA usage, etc.) Certificates (C of R, ARC, C of A, Noise cert, radio licence, etc)eu-ops subpart B Summary of certain mod and repair data such as flammability reports, electrical load data, etc. Dent & buckle chart and structural repair file (contents) DFDR readouts and conformity statements Oil / fuel analyses W&B loading manual (EU-OPS subpart J) Parking storage records Aircraft Flight Manual and STC supplements (EU-OPS subpart P) 15
16 Aspects of aircraft transitions Initial Airworthiness compliance Importing Authorities Sale conditions compliance Buyer/Owner Lease return conditions compliance Aircraft transition Aircraft Acceptance Lessor Importing Country Airworthiness compliance Purchase / Lease Agreement Acceptance cert Dropouts in ETA list New Operator 16
17 Organization of transitions Prepare (project milestones, resources, agree on acceptance standards) Budget (resources, EOL check, engine SV s, etc.) Time (acceptance milestones, reverse calculate) Verify everything before submittal Work together (check lists, minute meetings, human skills) 17
18 Thank You! Happy to take questions 18
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