Part 145 CONTINUATION TRAINING General Overview and introduction to the regulations Q3 & Q4 2017 Page 1 of 11
CONTENTS: 1 Introduction 2 In the Beginning 3 EASA 4 Regulation 5 How does this all work in practise? Page 2 of 11
1. Introduction The purpose of this module is to refresh Part145 knowledge, over the coming editions we aim to give a general overview and introduction to the regulations. We welcome feedback. 2. In the beginning. In 1944 the Convention on International Civil Aviation, also known as the Chicago Convention, established the International Civil Aviation Organization (ICAO), a specialized agency of the UN charged with coordinating and regulating international air travel. The Convention establishes rules of airspace, aircraft registration and safety, and details the rights of the signatories in relation to air travel. The Convention also exempts air fuels in transit from (double) taxation. ICAO works with the Convention s 192 Member States and industry groups to reach consensus on international civil aviation Standards and Recommended Practices (SARPs) and policies in support of a safe, efficient, secure, economically sustainable and environmentally responsible civil aviation sector. Page 3 of 11
3. EASA The European Aviation Safety Agency or EASA is an agency of the European Union with responsibility for civil aviation safety. It carries out certification, regulation, and standardisation, and performs investigation and monitoring. It collects and analyses safety data, drafts and advises on safety legislation, and coordinates with similar organisations in other parts of the world. The idea of a European-level aviation safety authority goes back to 1996, but the agency was not legally established until 2002. It began its work in 2003. EASA maintains close working relations with ICAO on a wide range of activities. Among others, EASA: Works with the European Commission and EASA Member States to coordinate common positions on matters addressed at global level. As EASA is not in itself a state, it supports on behalf of its Member States in implementing the ICAO standards. Exchanges safety information with ICAO Provides technical expertise to ICAO activities To demonstrate compliance with international aviation standards to ICAO, the European Parliament needed to pass some basic regulations 4. Regulations The Basic regulation was passed by the European Parliament. The principal objective of Regulation (EC) No 216/2008 (commonly referred to as "EASA Basic Regulation") is to establish and maintain a high uniform level of civil aviation safety in Europe by implementing common rules in the field of civil aviation and establishing an independent European Aviation Safety Agency overseeing the uniform implementation of all necessary acts by the national aviation authorities. What does this regulation structure look like? Page 4 of 11
Basic Regulation EC No216/2008 Continuing Airworthiness* Part145 Regulation Acceptable means of compliance & Guidance material The tasks of EASA include: Drafting of implementing rules Certification and & approval of products and organisations. Promoting the use of European and worldwide standards. EASA Publish regulations (hard law) these are otherwise known as Implementing Rules laying down technical requirements and administrative procedures related to civil aviation. One of these Implementing Rules covers. Continuing Airworthiness *Commission Regulation (EU) No 1321/2014 is the implementing rule on the continuing airworthiness of aircraft and aeronautical products, parts and appliances, and on the approval of organisations and personnel involved in these tasks This is further broken down into Parts or Annexes Part-M -regulates the continuing airworthiness of aircraft and aeronautical products, parts and appliances together with the approval of organizations and personnel involved in these tasks. Part-145- regulates the approval of aircraft maintenance organisations. Part-147- regulates the approval of maintenance training organisations Part-66 - regulates Certifying Staff. Part-T- regulates aircraft registered in a third country. Page 5 of 11
Regulations Structure Each Part to each implementing regulation has its own Acceptable Means of Compliance and Guidance Material (AMC/GM). These AMC and GM are amended along with the amendments of the regulations. These AMC/GM are so-called soft law (non-binding rules), and put down in form of EASA Decisions. A comprehensive explanation on AMC in form of questions and answers can be found on the FAQ section of the EASA website. Furthermore, Certification Specifications are also related to the implementing regulations, respectively their parts. Like AMC/GM they are put down as Decisions and are non-binding. BASIC REGULATION REGULATIONS ANNEXES Initial Airworthiness Additional airworthiness spec. Continuing Airworthiness Air Crew Air Operations Third country operators ANS common req. ATM/ANS safety oversight ATCO Licensing Airspace usage req. SERA Aerodromes I Part-21 Part-26 Part-M Part-FCL DEF Part TCO GEN Part-ACAS Rules of the air (RoA) DEF II Part-145 Conversion of national licenses Part-ARO Part ART ATS PART-ADR.AR III Part-66 Licenses of non-eu states Part-ORO MET PART-ADR.OR IV Part-147 Part-MED Part-CAT AIS PART-ADR.OPS V Part-T Part-CC Part-SPA CNS VI Part-ARA Part-NCC VII Part-ORA Part-NCO VIII Part-SPO FULL TITLES Commission Regulation (EU) No 748/2012 of 03/08/2012 laying down implementing rules for the airworthiness and environmental certification of aircraft and related products, parts and appliances, as well as for the certification of design and production organisations Commission Regulation (EU) 2015/640 of 23/04/2015 on additional airworthiness specifications for a given type of operations and amending Regulation (EU) No 965/2012 Commission Regulation (EU) No 1321/2014 on the continuing airworthiness of aircraft and aeronautical products, parts and appliances, and on the approval of organisations and personnel involved in these Commission Regulation (EU) No 1178/2011 of 3 November 2011 laying down technical requirements and administrative procedures related to civil aviation aircrew pursuant to Regulation (EC) No 216/2008 of the European Parliament Commission Regulation (EU) No 965/2012 of 5 October 2012 laying down technical requirements and administrative procedures related to air operations pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council Commission Regulation (EU) No 452/2014 of 29 April 2014 laying down technical requirements and administrative procedures related to air operations of third country operators pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council. Commission Implementing Regulation (EU) No 1035/2011 of 17 October 2011 laying down common requirements for the provision of air navigation services Commission Implementing Regulation (EU) No 1034/2011 of 17 October 2011 on safety oversight in air traffic management and air navigation services Commission Regulation (EU) 2015/340 of 20 February 2015 laying down technical requirements and administrative procedures relating to air traffic controllers' licences and certificates pursuant to Regulation (EC) No 216/2008... Commission Implementing Regulation (EU) No 1332/2011 of 16 December 2011 laying down common airspace usage requirements and operating procedures for airborne collision avoidance Commission Implementing Regulation (EU) No 923/2012 of 26/09/2011 laying down the common rules of the air and operational provisions regarding services and procedures in air navigation Commission Implementing Regulation (EU) No 139/2014 of 12/02/2014 laying down requirements and administrative procedures related to aerodromes pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council
So what do these regulations look like? The Implementing rule is quite prescriptive and sometimes may be hard to interpret, so for the sake of Legal Certainty that an organisation is following the intent of the rules, Acceptable means of Compliance (AMC) otherwise known as Soft law are provided to provide more clarity of this intent of the regulation to industry. Underpinning the AMC is Guidance Material, this shows industry Best Practice and it is not a requirement to always follow Guidance Material. So, a typical example is shown below: Page 6 of 11
Acceptable Means of Compliance (AMC) & Guidance Material (GM) to a Regulation Regulation Acceptable means of compliance. Guidance Material Page 7 of 11
Part-145 can be further broken down into paragraphs: These will all be discussed in a later edition From these paragraphs we have a requirement for a Maintenance Organisation Exposition (MOE) and its contents. Page 8 of 11
4. How does this all work in practise? Lets take an operator An Approved organisation able to conduct safe operations (was an AOC Air Operators Certificate - now a Licenced Air Carrier) working under Implementing Rule - Part ORO To become a Licenced Air Carrier (BA EasyJet, KLM, Air France etc.) they must have as part of their approval, a Part M CAMO (Continuing Airworthiness Management Organisation) to be able to demonstrate the continuing airworthiness of the operator s aircraft. The operator should have at least a Line Maintenance Part145 Approval -and so would be able to complete and certify (Release via a CRS Certificate of Release to Service) any maintenance due on the aircraft or component to conduct operations, we will discuss alternatives to this arrangement later. This is a classic inhouse organisation and the overlap between them all is a demonstration of this dependency. Page 9 of 11
Or alternatively The Altitude Global model Part 145 Continuation Training. The Part M CAMO may contract the services of, or provide individual Work Orders to a suitable approved Part 145 maintenance organisation Supporting the Part 145 will be: Part-147 Type Training Part66 type rated Certifying staff Part 145 C Rating- Component maintenance Part145 C Certifying staff Page 10 of 11
Next Edition The MOE Page 11 of 11