Continuing Airworthiness
Objectives To provide an overview of EASA Part M(g) as applicable to CAT operators Continuing Airworthiness Management Organisation approval The Controlled Environment Airworthiness Review Certificates (ARC) 2
Regulation Overview Council Regulation (EC) No 216/2008 (Basic Regulation) Annex I - Essential Requirements Annex II - Excluded Aircraft Annex III Pilot Licensing Annex IV Air Operations Established by the European Parliament Implementing Rules Articles 5 & 6 of Basic Regulation Commission Regulation (EC) No 748/2012, as amended (Certification) Annex I - Part 21 (Includes Noise and Environmental Requirements) Commission Regulation (EC) No 1321/2014, as amended (Continuing Airworthiness) Annex I Part M Annex II Part 145 Annex III Part 66 Annex IV Part 147 Established by the European Commission Binding in EU Law Article 19 of Basic Regulation Acceptable Means of Compliance (AMC) & GM (Certification) Certification Specifications Airworthiness Codes + associated AMC & GM (Certification & Continuing Airworthiness) AMC & GM (Continuing Airworthiness) Not Binding in EU Law EASA (The Agency) 3
Part M Section A Subpart A Subpart B Subpart C Subpart D Subpart E Subpart F Subpart G Subpart H Subpart I General Accountability Continuing Airworthiness Maintenance Standards Components Maintenance Organisation Continuing Airworthiness Management Organisation Certificate of Release to Service Airworthiness Review Certificate 4
Responsibilities 1) The operator is responsible for the continuing airworthiness of an aircraft and shall ensure that no flight takes place unless: 2) The aircraft is maintained in an airworthy condition; and 3) Any operational, emergency equipment systems fitted are correctly installed and serviceable or clearly identified as unserviceable; and 4) The airworthiness review certificate remains valid; and 5) All aircraft maintenance is performed in accordance with the Approved Maintenance Programme. 5
Responsibilities The operator shall be responsible for the satisfactory accomplishment of the pre-flight inspection. Maintenance of large aircraft, aircraft used for commercial air transport and their components shall be carried out by Part-145 approved maintenance organisations. 6
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Responsibilities Responsibilities For holders of an Air Operators Certificate (AOC) Must be approved to Part M subpart G, for the aircraft it operates (as part of the AOC) Be approved to Part 145 or have a contract with one Copyright 2011 CAA International Ltd Part M; V01 9
Occurrence Reporting Any person or organisation responsible under M.A.201 shall report any identified condition of an aircraft or component which endangers flight safety to the following: i. Competent authority of the state of registry ii. TC / STC holder iii. Member state of operator iv. Report to the owner, the operator or managing CAMO Reports shall be made as soon as practical but within 72 hours 10
Continuing Airworthiness The aircraft CAW and the serviceability of both operational and emergency equipment shall be ensured by: 1) The accomplishment of pre-flight inspections 2) The rectification of any defect and damage affecting safe operation taking in to account the MEL. 3) The accomplishment of all maintenance, in accordance with the approved Aircraft Maintenance Programme (AMP) 4) The analysis of the effectiveness of the AMP 11
Continuing Airworthiness The AMP must establish compliance with: a) Instructions issued by the competent authority, b) Instructions for CAW (ICAW) issued by TC, Restricted TC and STC holders, major repair design approval, ETSO authorisation and any other relevant approval holder that publishes such data 12
Continuing Airworthiness c) This may include: Lubrication tasks Inspection tasks (E.G: GVI, DVI or NDT) Component tasks Operational /Functional checks Life limitations 13
Continuing Airworthiness 5) The accomplishment of any applicable: i. Airworthiness Directive (a) (b) (c) (d) State of Design Airframe, Engine, Propeller, Equipment. State of Design for STCs EASA State of Registry 14
Continuing Airworthiness 5) The accomplishment of any applicable: ii. Any Operational directive with a continuing airworthiness impact iii. Continued airworthiness requirement established by the EASA iv. Measures mandated by the competent authority in immediate reaction to a safety problem 15
Continuing Airworthiness 6) The accomplishment of modifications and repairs in accordance with M.A.304 7) For non-mandatory modifications and/or inspections, the establishment of an embodiment policy 8) Maintenance check flights when necessary 16
Continuing Airworthiness 17
Continuing Airworthiness 18
Continuing Airworthiness The aircraft CAW records shall consist of, as appropriate, An aircraft logbook Engine logbook(s) or engine module log cards, Propeller logbook(s) Log cards for any service life limited component Component authorised release document i.e EASA form 1 19
Continuing Airworthiness Operator s technical log system a) Shall contain the following information: 1) Flight safety information 2) Current CRS 3) Current maintenance statement 4) Outstanding deferred defects (ADDs) 5) Maintenance support arrangements 20
Continuing Airworthiness Operator s technical log system (cont) b) Operators technical log system and subsequent amendments shall be approved by the authority c) Operator shall ensure the technical log is retained for 36 months after the last entry. 21
Continuing Airworthiness Management Exposition (CAME) The CAME contains 7 parts Part 0 - General Organisation (Including corporate commitment) Part 1 - Continuing Airworthiness Management Procedures Part 2 - Quality System Part 3 - Contracted Maintenance Part 4 - Airworthiness Review Procedures Part 4B Permit to Fly Procedures Part 5 - Appendices 22
Facilities The CAMO shall provide suitable office accommodation at appropriate locations 23
Personnel Requirements 1) Accountable Manager. 2) Management personnel. 3) For CAT, a nominated post holder responsible for management and supervision of CAW activities. 4) All persons shall be able to show relevant knowledge, background and appropriate experience relating to aircraft CAW 5) For CAT and Large aircraft, the organisation is required to establish and control the competence of all personnel involved in continuing airworthiness management, airworthiness reviews and / or quality audits. 24
Example Organisation Structure Nominated post holder for CAW required for CAT Accountable Manager Nominated post holder Quality Assurance Contracts Technical Records Planning Airframe Engines Avionics 25
Airworthiness Review Staff To be approved to carry out airworthiness reviews, a CAMO shall have appropriately qualified airworthiness review staff to issue ARCs or make recommendations and if applicable to issue a Permit to Fly 26
Continuing Airworthiness Management All continuing airworthiness management shall be carried out according to the prescriptions of M.A. Subpart C. 1) Develop and control a maintenance programme for the aircraft managed including any applicable reliability programme; 2) Present the aircraft maintenance programme and its amendments to the competent authority for approval 3) Manage the approval of modifications and repairs 27
Continuing Airworthiness Management 4) Ensure that all maintenance is carried out in accordance with the approved maintenance programme and released by Part 145 approved maintenance organisations; 5) Ensure that all applicable airworthiness directives and operational directives with a continuing airworthiness impact, are applied; 6) Ensure that all defects discovered during scheduled maintenance or reported are corrected by an appropriately approved maintenance organisation; 28
Continuing Airworthiness Management 7) Ensure that the aircraft is taken to an appropriately approved maintenance organisation whenever necessary; 8) Co-ordinate scheduled maintenance, the application of airworthiness directives, the replacement of service life limited parts, component inspection and to ensure the work is carried out properly; 9) Manage and archive all continuing airworthiness records and the operator's technical log; 10) Ensure that the mass and balance statement reflects the current status of the aircraft. 29
Airworthiness Review To ensure the validity of the airworthiness certificate, an AR shall be carried out periodically. 1) Review of aircraft records 2) Physical survey of aircraft Note: Airworthiness Review tasks cannot be sub-contracted 30
Airworthiness Review A full documented review of the aircraft records to be satisfied that: 1) airframe, engine and propeller hours / cycles have been properly recorded 2) the flight manual is up to date and reflects the A/C configuration 3) all due maintenance has been carried out iaw AMP 4) all known defects rectified or appropriately carried forward 5) all applicable ADs have been applied / recorded 31
Airworthiness Review 6) all modifications and repairs are approved and correctly applied, and; 7) all service life limited components installed are within the approved life limits, and; 8) all maintenance has been correctly released, and; 9) the current mass and balance statement reflects the configuration of the aircraft and is valid, and; 10) the aircraft complies with the latest revision of its approved type design, and; 11) if required, the aircraft holds a noise certificate corresponding to the configuration of the aircraft 32
Airworthiness Review The approved airworthiness review staff shall carry out a physical survey of the aircraft. If the airworthiness review staff are not appropriately qualified to Part-66 they shall be assisted by someone that is. 33
Airworthiness Review The physical survey of the aircraft shall ensure that: 1) all required markings and placards are properly installed, 2) the aircraft complies with its approved flight manual, 3) the aircraft configuration complies with the approved documentation, 4) no evident defect can be found that has not been appropriately addressed, 5) no inconsistencies can be found between the aircraft and documented records 34
Privileges of the Organisation A1) Manage the continuing airworthiness of non-cat aircraft as listed on the approval certificate and CAT aircraft when listed on both the approval certificate and AOC. A2) Arrange to carry out limited CAW tasks with any organisation working under under its quality system as listed on the approval certificate. (subcontracting) A3) Extend any ARCs issued by the CAA or by another appropriately approved CAMO (subject to meeting the applicable requirements of subpart I) 35
Privileges of the Organisation B1) Issue an Airworthiness Review Certificate (ARC) and extend it in accordance with Subpart I. B2) Make a recommendation to the competent authority of the state of registry to issue an ARC C) Issue Permits to Fly in accordance with Part 21 Note: Privileges - A Privileges - A + B Privileges - A + B + C 36
Quality System To ensure CAMO continues to meet the requirements of Part M, it shall establish a Quality System and designate a Quality Manager to monitor compliance with and adequacy of procedures required to ensure an airworthy aircraft. Compliance monitoring shall include a feedback system to the Accountable manager to ensure corrective action as necessary Accountable Manager Nominated post holder Quality Assurance 37
Quality System The Quality System shall monitor: Compliance with Part M Maintenance is carried out iaw the contract CAW activities performed iaw approved procedures Records shall be kept for at least two years 38
Quality System The Quality System can be combined with another approval. (e.g. Part-145) In the case of Commercial Air Transport, the Quality System shall be an integrated part of the operators quality system. Quality System Subpart G AOC 39
Changes to the Organisation The CAMO shall inform the competent authority (CAA) of any of the following changes Name of organisation Location of organisation Additional locations Accountable manager Management personnel Scope of work, facilities, staff, procedures that could effect the approval 40
Record Keeping The CAMO record all details of work carried out. Records required by M.A.305 & 306 A copy of each ARC issued, recommended or extended including supporting documents Retain records for up to 24 months after the A/C is permanently withdrawn from service Records protected from damage, theft and alteration Computer back-ups stored in a different location from the working data 41
Airworthiness Review Certificate To ensure the aircraft remains airworthy, a review of the aircraft and its records must be carried out periodically. Patch repair 42
Airworthiness Review Certificate The Controlled Environment An aircraft in a controlled environment is an aircraft continuously managed by a unique M.A. Subpart G approved continuing airworthiness management organisation in the previous 12 months, and; Which has been maintained for the previous 12 months by approved maintenance organisations (Part 145). 43
Airworthiness Review Certificate An Airworthiness Review Certificate is valid for 12 months. Aircraft in a controlled environment may have the ARC extended twice and only require a full airworthiness review to be carried out every three years. Aircraft that are not in a controlled environment, the ARC cannot be extend, a full airworthiness review will be required every year. An ARC can only be issued or extended if the aircraft remains airworthy. 44
Aircraft Airworthiness Review Pattern A/C in Controlled Environment 12 Months 12 Months 12 Months AR Extend Extend AR A/C not in a Controlled Environment 12 Months 12 Months 12 Months AR AR AR AR 45
Aircraft Airworthiness Review Pattern To allow the physical review to take place during a maintenance check, the airworthiness review can be anticipated by a maximum period of 90 days without loss of continuity. AR Extend Extend 12 Months 12 Months 12 Months 30 Days 90 Days It is acceptable to anticipate the extension of the ARC by a maximum of 30 days without a loss of continuity of the airworthiness review pattern, which means that the new expiration date is set up one year after the previous expiration date. If the ARC is extended after its expiry, the new expiry date is the same as it would have been if extended at the correct time 46
ARC valid for twelve months Statement to confirm aircraft is airworthy and in a controlled environment (1 st extension) Statement to confirm aircraft is airworthy and in a controlled environment (2 nd extension) 47
Continuing Airworthiness Management Organisation Approval 48
Summary 1) Part M Subpart G is an approval to manage aircraft continuing airworthiness. The privilege can also be extended to include the issue of Airworthiness Review Certificates (or making recommendations to the CAA for the issue of Airworthiness Review Certificates) and the issue of Permits to Fly. 2) All Cat aircraft must be managed by a Subpart G organisation that is part of the AOC. 3) All maintenance must be performed by Part 145 approved organisations 49
Summary 4) The Quality system of the Subpart G must be an integral part of the operators Quality system. 5) An Airworthiness Review Certificate for all aircraft can only be extended by an appropriately approved) Subpart G organisation, when the aircraft has remained within their controlled environment. 50
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