Continuing Airworthiness update Juan Anton Maintenance Regulations Section Manager Flight Standards Directorate EASA E&M Sub-SSCC 02 June 2015 TE.GEN.00409-001
Recast of Regulation 2042/2003 and upcoming Regulations (1/2) Reg (EU) 1321/2014 Recast: repeals Reg(EC) 2042/2003 and amendments ( official consolidation ) Published on 17th December 2014. Entered into force on 6th January 2015. The only new requirement Part-66 Appendix III: training shall comply with mandatory part of Operational Suitability Data (OSD). Application in art 6(3): type training courses approved before approval OSD shall include mandatory part not later 18 Dec 2017 or within 2 years (latest) Contains reference to Reg(EC) 2042/2003 in the approval certificates. 7th Airworthiness Standardisation Meeting 2
Recast of Regulation 2042/2003 and upcoming Regulations (2/2) Opinions voted favourably in the EASA Committee in July 2014 Finalising the Scrutiny process 2 additional Regulations, amending the recast, are expected to be adopted 2nd quarter 2015 1 st amending regulation includes: Changes linked to Part-M GA Phase I (Opinion 10/2013) Changes to reg number in the approval certificates Immediate applicability (20 days after publication) Change of the date for the Opt-out to aircraft maintenance licenses for ELA1 not involved in commercial air transport, until 28 September 2015 2016 2 nd amending regulation includes: Changes linked to ACAM opinion (Opinion 02/2013) Changes linked to critical tasks opinion (Opinion 06/2013) Changes linked to alignment to BR opinion. These are the changes from large aircraft to CMPA, changes to M.A.201 for the different types of operations, the new Part-T for dry lease of third country registered aircraft by licensed air carriers (Opinion 06/2012) Applicability on 25 August 2016 with different opt-outs until 2017. 7th Airworthiness Standardisation Meeting 3
Opinion not voted yet Task 145.017 Control of suppliers for components, parts and appliances Clarify the requirements and produce guidance on how to evaluate component suppliers. Evaluate the possibility to use industry standards and accreditation programmes in order to reduce the auditing burden when a supplier is used by many maintenance organisations. Opinion 12/2013 was published in December 2013. This Opinion has not been discussed yet at the EASA Committee. 7th Airworthiness Standardisation Meeting 4
Draft Rulemaking Programme (1/3) TASK NUMBER DESCRIPTION DELIVERABLE COMMENTS TOR NPA CRD/ Opinion RMT.0135 (66.027 a) B2L and L licence X X 2015 Opinion 2Q 2015 RMT.0541 RMT.0245 (MDM.048) RMT.0281 (MDM.082) Appendix I Aircraft type ratings for Part-66 Standard aircraft changes and repairs New training methods/ New Teaching technologies X X 2015 Decision 2Q 2015 - Recurrent. X X 2015 Decision 2Q 2015 X X 2016 Opinion 1Q 2016 RMT.0393 (OPS.097 a) Maintenance check flights X X 2016 Opinion 3Q 2016 RMT.0276 (MDM.076) Technical records X X 2016 RMT.0209 (M.014 a) RMT.0217 (M.029) Contracting of continuing airworthiness CAMO and Part-145 responsibilities X X 2016 X X 2017 RMT.0251 (MDM.055) SMS into 1321/2014 X X 2018 RMT.0097 (145.024) Functions of B1 and B2 support staff X X 2018 Opinion 3Q 2016 -Opinion4Q 2015 (CAMO) -New NPA in 2017 with new approach (Part-145, Part-147, POA, Section B ) RMT in green more information in next slides ( recent ) 7th Airworthiness Standardisation Meeting 5
Draft Rulemaking Programme (2/3) TASK NUMBER DESCRIPTION DELIVERABLE COMMENTS RMT.0547 RMT.0521 RMT.0278 (MDM.078) RMT.0106 (21.039 e) Task force for the review of Part- M for General Aviation (Phase II) Review of airworthiness review process Importing of aircraft from other regulatory systems CS and GM for Maintenance certifying staff TOR NPA CRD/ Opinion X 2016 NPA 2Q 2015 X 2017 NPA 3Q 2015 X 2017 NPA 4Q 2015 X 2018 NPA 4Q 2015 RMT.0544 Review of Part-147 2018 NPA 4Q 2015 RMT.0537 Privilege for CAMOs to issue Flight Conditions 2017 NPA 4Q2016 RMT in green more information in next slides ( recent ) 7th Airworthiness Standardisation Meeting 6
Draft Rulemaking Programme (3/3) TASK NUMBER DESCRIPTION DELIVERABLE COMMENTS TOR NPA CRD/ Opinion RMT.0252 (MDM.056) sub 1 Instructions for continuing airworthiness (ICA) X 2018 Certification RMT.0252 (MDM.056) sub 2 Instructions for continuing airworthiness (ICA) X 2018 Certification RMT.0252 (MDM.056) sub 3 Instructions for continuing airworthiness (ICA) X 2018 Replaced by a certification procedure RMT.0252 (MDM.056) sub 4 Instructions for continuing airworthiness (ICA) X 2018 Certification RMT.0252 (MDM.056) sub 5 RMT.0096 (145.023) Instructions for continuing airworthiness (ICA) Procedures for foreign Part-145 approvals X X X 2018 Certification Put on hold in order to assess the feasibility to be continued RMT.0255 (MDM.059) Miscellaneous of Part 66 X Task on hold RMT.0243 (MDM.042) Major configuration differences X RMT.0368 (MDM.091) RMT.0211 (M.020) Protection against the use of contaminated halon Recurrent defects on components Task deleted SIB to be issued. Task deleted SIB to be issued. Task deleted SIB to be issued. 7th Airworthiness Standardisation Meeting 7
Opinions/Decisions to be issued shortly Task RMT.0135 Avionic licence for general aviation and licence for sailplanes, balloons, airships and ELA1 aeroplanes (1/2) B2L licence: this is a simplified avionics licence for all aircraft except those in Group 1 (the complex ones). This licence will be divided in the following system ratings: Communication / Navigation Instruments Auto-flight Surveillance Airframe systems L-licence: this is a very simple licence for the most simple aircraft. This licence covers: sailplanes powered sailplanes and ELA1 aeroplanes balloons hot air airships and ELA2 gas airships gas airships above ELA2 7th Airworthiness Standardisation Meeting 8
Opinions/Decisions to be issued shortly Task RMT.0135 Avionic licence for general aviation and licence for sailplanes, balloons, airships and ELA1 aeroplanes (2/2) NPA 2012-15. A total of 124 comments addressed in CRD 2012-15. Opinion expected 2nd quarter 2015. Introduces a change in dates in Article 8 Entry into force for the maintenance of ELA1 aeroplanes not involved in commercial air transport (to be discussed in EASA Committee), (i) until 28 September 2018, the requirement for the competent authority to issue aircraft maintenance licences in accordance with Annex III (Part-66), as new or as converted pursuant to point 66.A.70 of the same Annex; (ii) until 28 September 2019, the requirement to have certifying staff qualified in accordance with Annex III (Part- 66) contained in the following provisions: M.A.606(g) and M.A.801(b)2 of Annex I (Part-M), 145.A.30(g) and (h) of Annex II (Part- 145). 7th Airworthiness Standardisation Meeting 9
Opinions/Decisions to be issued shortly Task RMT.0245 CS for standard changes and repairs Allows the embodiment of standard changes/repairs on certain aircraft when defined conditions are fulfilled (without a design approval). Document similar to the FAA AC 43-13 but replacing the field approval of the FAA system (which does not exist in Europe) by the release issued by Part-66 certifying staff. Proposed NPA refers to certain repairs/changes included in FAA AC43-13 and in certain existing national documents. NPA 2014-24 published in October 2014. 370 comments received. Decision 2 nd quarter 2015. Phase II to develop further standard repairs/changes. 7th Airworthiness Standardisation Meeting 10
Opinions/Decisions to be issued shortly Task MDM.082 New training/teaching technologies NPA 2014-22 published in September 2014. Workshop performed in September 2014. 410 comments received Most of the comments are favourable, but proposing simpler, better solutions, or better wording. Many comments received (along with the proposals for change) on Appendix VII Assessment method for multimedia-based training (MBT) systems and the assessment table. Two Review Group meetings in 2015 Opinion 1 st quarter 2016 7th Airworthiness Standardisation Meeting 11
Opinions/Decisions to be issued shortly Task RMT.0393 Maintenance check flights Issues addressed: Flight programme preparation, crew selection and qualification, personnel on board, interfaces with CAMOs, aircraft status. ELA1 and ELA2 aircraft excluded. After the CRD 2012-08, some organisations have requested to change/remove the proposed experience requirements (number of Flight Hours) for the flight crew and to leave it more to the call of the operator (SMS / Performance Based Rules). Coordination is being performed with the task RMT.0348 Flights related to Design/Production before issuing an Opinion 3 rd quarter 2016 7th Airworthiness Standardisation Meeting 12
Opinions/Decisions to be issued shortly Task RMT.0276 Technical records The objective is to clarify the following: Inconsistency in the use of terms such as Life Limited Parts and Service Life Limited Parts Whether Back to birth traceability is needed. Guidance on the use of electronic signature, the acceptability of scanned record copies and the use of new technology such as RFID (Radio Frequency Identification). NPA 2014-04 was published in February 2014. 350 comments received. Two review group meetings in 2015. Some comments: Time Controlled Components: definition and status including life accumulated by component General aviation: consistency with work in Part-M GA (Phase II), summary entries in the logbooks In-service history record for each Life Limited Part Records keeping period Opinion 3 rd quarter 2016 7th Airworthiness Standardisation Meeting 13
Opinions/Decisions to be issued shortly Task M.014 Contracting of continuing airworthiness management activities To allow any CAT operators to contract its continuing airworthiness management to an external CAMO and remove the requirement to hold a CAMO approval themselves Task is necessary to support the development of more efficient business models NPA 2010-09 published in July 2010 Highly controversial task (total support from Industry, significant rejection from certain NAAs) EASA will discuss the issue with dissenting NAAs EASA will work on issuing an opinion in coordination with second phase of SMS, for consistency purposes, to be published in 2016 7th Airworthiness Standardisation Meeting 14
Opinions/Decisions to be issued shortly Task MDM.055 SMS embodiment and alignment with AR/OR requirements NPA 2013-01 published on 21 January 2013. Covers Part-M and Part-145 (aprox 1300 comments) NPA 2013-19 published on 10 October 2013. Covers Part-147, -66 (aprox 190 comments) The intention is to split the task: Since Part-M is linked to the operator (OPS rules require SMS) Opinion (covering only CAMOs) in 2015 based on the published NPA. For Part-145, Part-147, POA, DOAs and Section B, there will be a new reevaluation (and new NPA). 7th Airworthiness Standardisation Meeting 15
NPAs to be issued shortly Task RMT.0547 Task force for the review of Part-M for General Aviation (Phase II) Some expected features: Light Part-M (new Annex VI to Reg(EU) 1321/2014). Organisation requirements (CAMO, Subpart F organisations) kept in Part-M; Applicable to all ELA2 aircraft plus those helicopters certified for up to 4 occupants up to 1200 Kg MTOM, regardless of type of operation; Owners/operators can choose to apply Part-M or Part-ML; Defects Management: Defect on non-required equipment may be deferred by the pilot, Defect on required equipment to be deferred using MEL, Other defect may be deferred by the pilot with the authorisation of the owner (only for non-commercial aircraft) NPA to be published in 2 nd quarter 2015 7th Airworthiness Standardisation Meeting 16
NPAs to be issued shortly Task RMT.0521 Review of the airworthiness review process Discussion on the following: Structure of the requirements Need for and definition of controlled environment Recommendations (as an intermediate step before the authority issues the ARC) Independence from the airworthiness review process and from the maintenance release of the aircraft (AMC M.A.707(a)). Sampling of documents during the airworthiness review Content of the review Open findings when issuing an ARC Control of the airworthiness review process and prospective effects if more than one person is involved, including staff entitled to perform the airworthiness review and staff entitled to sign the ARC. Transfer between Member States. NPA expected 3 rd quarter 2015 7th Airworthiness Standardisation Meeting 17
NPAs to be issued shortly Task RMT.0278 Importing of aircraft from other regulatory systems Objectives: Mitigate potential safety risks linked to the fact that the aircraft did not comply with the EU rules prior to being registered/imported, and to facilitate a common understanding of the approach to be followed, in terms of recognition of other certificates and/or records issued by other stakeholders to the aircraft involved, Clarify current ambiguities in the rules related to issuance of CofAin order to achieve standardised implementation and equal treatment in all Member States. NPA expected 4 th quarter of 2015. 7th Airworthiness Standardisation Meeting 18
NPAs to be issued shortly Task RMT.0106 CS and GM for maintenance certifying staff type rating training Main objective: improve the level of safety by requiring the applicant for a TC or Restricted TC for an aircraft to identify the minimum syllabus of maintenance certifying staff type training, including the determination of type rating. This minimum syllabus, together with the requirements contained in Part-66, will form the basis for the development and approval of Part-66 type training courses. NPA 4 th quarter 2015 7th Airworthiness Standardisation Meeting 19
NPAs to be issued shortly RMT.0544 Review of Part-147 Address the safety-critical issues as fraud by Part-147 organisations during basic examinations not linked to a basic training course NPA 4 th quarter 2015 7th Airworthiness Standardisation Meeting 20
NPAs to be issued shortly RMT.0537 Privilege for CAMOs to issue Flight Conditions Draft ToR sent for comments NPA 4 th quarter 2016 7th Airworthiness Standardisation Meeting 21