ARSA Symposium March 2017 Breakout Session 2: International Certification of Maintenance Organizations Helio Tarquinio Junior
ICAO Standards and Recommended Practices Mutual recognition of AMO certification and surveillance findings
ANAC Point of View Aeronautical Maintenance Organizations (AMOs) that provide services to international operators often must meet numerous requirements and maintain numerous endorsements from different State of Registry. This imposes an additional burden on AMOs and Civil Aviation Authorities (CCAs), which could be avoided if countries recognize the approvals of foreign AMOs.
ICAO Actions In 2010, during the High Level Safety Conference (HLSC), ICAO proposed to create a working group to address this issue. In 2012, a working group was created at the ICAO Airworthiness Panel (AIRP) to develop provisions, support material and guidance for the harmonization and global recognition of AMOs approvals; The working group is currently working on the move of the requirements for AMOs from Annex 6 to Annex 8 and the matching of related documents. ICAO Working Papers Approval and Global Recognition of Aircraft Maintenance Organizations (AMOs) Phase 1, Doc 9760 and Phase 2, Annexes.
Brazil participates in the AIRP working group. ANAC Actions Brazil has agreements for the acceptance of AMOs with TCCA since 2005. Brazil has agreements for the acceptance of AMOs with EASA since 2016. Brazil is currently working on the development of the agreement with the FAA. Brazil participates in SRVSOP meetings for its inclusion in the multilateral agreement on acceptance of the AMOs in Latin America. Brazilian Requirements have already adjusted to reflect the transfer of the requirements for AMOs from Annex 6 to Annex 8.
ANAC AMO Certificate Process Current Scenario in USA ANAC AMOs in USA ANAC Certified Bases 127 In Certification Progress 5
Current Scenario ANAC/FAA requirements Similar Regulation between Brazil and US ANAC FAA RBAC 21 PART 21 RBAC 43 PART 43 RBAC 145 PART 145 IS Instrução Suplementar AC Advisory Circulars MPR Manual de Procedimentos Orders ANAC AMO Certificate Process *Historically, the Brazilian regulation for aircraft certification and operational airworthiness are based on FAA standards.
ANAC AMO Certificate Process General Rule RBAC 43 section 43.3: Persons authorized to perform maintenance, preventive maintenance, rebuilding, and alterations. Item (e): The holder of a repair station certificate may perform maintenance, preventive maintenance, and alterations as provided in RBAC145. Therefore, to perform maintenance in Brazilian aeronautical products it's required to hold an ANAC Repair Station certificate.
ANAC AMO Certificate Process Special case RBAC 43 section 43.17: (b)-i: Foreign repair stations, not certified by ANAC, may perform maintenance, preventive maintenance, rebuilding and alteration and approve the return to service of articles, not aircraft, complete engine and propeller, only under the following conditions: (1) ANAC has expressly manifested compatibility between regulation of maintenance functions of aeronautical products from Brazil and the Local Civil Aviation Authority; (2) The Repair Station is certified by the local Civil Aviation Authority and has capacity certified in the service intended to perform; Ordinance Nº 3109/SAR, 24/12/2014 ANAC stated the equivalence between regulatory systems for the US maintenance functions and Brazil.
Special case ANAC AMO Certificate Process According with RBAC 43 section 43.17 and Ordinance 3109/SAR : Repair Stations certified FAA inside the USA may perform maintenance, preventive maintenance, rebuilding and alteration and approve the return to service of articles, not aircraft, engine and propeller complete. Not required to hold a ANAC Repair Station Certificate in case of components maintenance. The maintenance performed according with stated above imposes to the responsible for the aircraft's airworthiness control the obligation to ensure compliance with RBAC 43. To perform Maintenance in Brazilian Aircraft, Engine and Propeller its required to hold an ANAC Repair Station certificate.
ANAC AMO Certificate Process Audit on foreign AMOs Activity Primary Certification Audit Certification Audit FAA/Other EASA / TCCA 2 ANAC Inspectors, at least 2 days audit In accordance with Bilateral Agreement FAA Documental Analysis * Renewal Audit EASA / TCCA Other In accordance with Bilateral Agreement 2 ANAC Inspectors, at least 2 days audit * Audit is not required, but if ANAC deems necessary may perform audit to the renewal of the certificate.
Hélio Tarquinio Júnior General Manager Continuous Airworthiness General Branch Department of Airworthiness Phone: +55 61 3314 4849 E-mail: helio.tarquinio@anac.gov.br www.anac.gov.br