overview of initial findings from european military...

Overview of initial findings from European Military Airworthiness Requirements (EMAR) 66 study

Mr Bob Simmons – Technical Director

MAWA Airworthiness ConferenceWarsaw - July 2011

Scope

• Maintenance system background

• Progress

• Level 1 Questionnaire & Initial Analysis

• Next Phase

• Level 2 Questionnaire

• Key Dates

• Summary

• Questions

© Baines Simmons Limited 2011 2

Parts Tag / Certificate

Engineer’s License

Work Order / Contract

Approved data

Maintenance SystemBackground


MaintenanceOrganisation

(Part 145)

ProductionOrganisation

(Part 21G)

Maintenance Training School

(Part 147)

LicensedEngineer(Part 66)

DesignOrganisation

(Part 21J)

ApprovedDesign / Data

ApprovedParts

CtAw ManagementOrganisation –

CAMO (Part M - G)

ApprovedMaintenanceProgramme

Organisation approval codes are designed to

cohesively fit together and enable mutual acceptance

through standardisation




(Part 145)

ProductionOrganisation

(Part 21G)

Maintenance Training School

(Part 147)

DesignOrganisation

(Part 21J)

CtAw ManagementOrganisation –

CAMO (Part M - G)

Approved organisations are standardised through Competent Authorityoversight and EASA standardisation audits. This enables the

organisations to accept the flow of people, parts, design data and work instructions without further showing

Parts Tag / Certificate

Engineer’s License

Work Order / Contract

Approved data




(Part 145)

The flow of people, parts, design data and work instructions between the various parties in the system is facilitated by certificates and contracts.

The License issued to an engineer allows the maintenance organisation to authorise that person, with the confidence that they have met basic

knowledge, experience and training requirements.

The basis of the EASA Part 66 License

The EASA Part 66 Maintenance Engineers Licenses has multiple uses:• Demonstration that a minimum level of knowledge has

been achieved by the holder to support the issue of a Part 145 Certifying Staff Authorisation

• When Type Rated to cover specific aircraft types (or groups), may be used as authority to certify maintenance completed on those non-commercial light aircraft

The same uses may not be needed for EMAR-66


Study progress

Phase 1 data gathering commenced in February• Note that 50+ responses were possible, as some pMS

have different authorities for Air Force, Army, Navy & State Aircraft maintenance

• Phase 1 report has been presented to TF3. the report presents a high-level analysis of the data collected

Phase 2 data gathering from TF3 members is nearing completion• Analysis to commence in July

Phase 3 development of recommendations • Planned for commencement in mid - July


Objectives of Phase 1

Establish pMS regulatory structure for maintenance

Understand pMS maintenance arrangements

Ascertain types of aircraft systems being maintained by pMS

Ascertain pMS ‘Basic’ maintenance certification qualifications

Ascertain pMS ‘Type’ maintenance certification qualifications

Establish opinion on potential for a common minimum requirement for a maintainer licensing or qualification system


Initial Analysis (1) – Key Points

Data supplied was of good quality

Data provides working overview of current pMS systems

Illustrates diversity between pMS:

• Maintenance terms

• Aircraft trade structures

• Qualification and certification systems

• Contractual arrangements



A significant number of pMS already use EASA or an adaption of EASA regulations:



A number of pMS already use EASA Part 145 (or an adaptation) for their contracted out maintenance contracts:



Adaptation of EASA Part 66 is already underway in some pMS (for basic and type qualifications):

….for example, France uses FRA 66 (again based upon EASA Part 66).

This is similar for civilian staff, but no pMS incorporates a specific ‘B Mil’ weapons trade:


Initial Analysis (5) – BenefitsSo, pMS are currently training their personnel based upon EASA

Part 66 or their own national requirement.....but no formal recognition of other pMS certifying qualifications:

EMAR 66 would provide a minimum requirement, for training and examination prior to qualification, to assure airworthiness.These qualifications would be considered when issuing licences and/or

Part 145 authorisations.

Potential for cross-servicing opportunities exist, with several aircraft types already identified:


Initial Analysis (6) – BenefitsSnapshot of charts of aircraft cross-serving opportunities:


Initial Analysis (7) – BenefitspMS show support for component maintenance under EMAR 66,

with potential for cross-servicing and/or shared inventories:

….but there are reservations about the difficulty with the inclusion of component maintenance staff and about the benefits of doing this.

Opportunities would exist for joint aerospace programmes:


Phase 2 data gathering(1) - Outline

Phase 2 data gathering:

• Include subjects, identified from the Level 1 questionnaire, which need to be clarified further

• Explore any problem areas identified by TF 3

• Detailed questions about maintenance certification authorisation

• Using EASA Part 66 as a baseline

• Proposed target date for responses: 30th June 2011


Level 2 Questionnaire (2) - Training

Conducted with ten pMS, with more detail about their ‘Basic’ and ‘Type’ training schemes:• Who provides training?

• How are courses approved?

• Where is training conducted?

• Are there any pre-requisites for training?

• What is taught?

• How are examinations conducted?

• Is post-course accreditation controlled?


Level 2 Questionnaire (3) - Authorisations

Detail about their certification authorisation procedures:• How are certification authorisations issued?

• Which Competent Authority provides procedural oversight ?

• How are procedures reviewed and amended?

• How are the procedures audited?

What are their certifying staff maintenance privileges?

Do they recognise continued validity of authorisations?

How are authorisations recorded?

How do they revoke, suspend or limit authorisations?


Level 2 Questionnaire (4) - Authorisations

More detail about their certification authorisation procedures:

• What are the minimum competency requirements?• Qualification, Knowledge, Experience

• Are partial credits awarded / taken into account?• Non-aircraft maintenance experience

• Ex-military rank and experience

• Protected ‘grandfather’ rights

• Previous examination credits

Is there a procedure to convert previous authorisations?


Level 2 Questionnaire (5) - AML

Aircraft Maintenance Licences (AML) – if used:

What is the application procedure?

How are the following aspects controlled?• Examinations prior to AML issue

• AML initial issue, renewals or conversion

• Amendment of AML ‘Basic’ category / sub category

• Amendment of AML ‘Type’ category

• AML revocation, suspension or limitation


Level 2 Questionnaire (6) – Knowledge

How is ‘Basic’ training divided up?• Standardised knowledge modules , bespoke courses, etc

What are their ‘Basic’ and ‘Type’ trade standards based upon?

What subjects are controlled by ‘Basic’ trade standards?• Maths, physics, electrics, electronics, materials, etc

What subjects are controlled by ‘Trade’ standards?• Zonal areas, airframe structure, air supply, hydraulics, etc

What rules apply to their ‘Basic’ and ‘Type’ trade examinations?• How often are examination questions revised?


Summary

Phase 1 data gathering has returned useful information to date....we did not seek to develop solutions at this stage!

Similar methodology has been used for Phase 2 data gathering

Early indications show pMS support for EMAR 66....whatever form it takes!

• Any questions?


[email protected]

mailto:[email protected]�

overview of initial findings from european military...

Documents