what+is+easa+part m+continuing+airworthiness

7/28/2019 What+is+EASA+Part M+Continuing+Airworthiness

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129 February 2012 Aviation Conference in Norway (Bodo)

What is EASA Part-M,Continuing Airworthiness?

Evolution in General Aviation

Juan AntonContinuing Airworthiness Manager

Rulemaking DirectorateEASA


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What happened in the old times ?

Before the existence of EU rules:

Every Member State had its own national aviation rules.

They covered all aviation aspects: operations, licensing,maintenance, certification, airports, air navigation, etc.

This had the advantage of having all these aspects underthe control of the same Member State but it was certainlydifficult to move goods/services/licensed personnelbetween different Member States.

Some Member States had their own bilateral agreementsand working arrangements with other states andauthorities.


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A first step into standardisation

The first step into standardisation was the introduction ofJAA requirements:

They covered only certain aviation aspects and only forcertain aircraft categories and operations, such as: JAR-145

JAR-66 JAR-OPS1 JAR-FCL

The implementation was voluntary for each Member Stateand could only happen if adopted in the national law.

Each Member State had the option to decide whetherthey wanted to be standardised (through inspections) ornot.


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Introduction of EU rules

The Basic Regulation EC1592/2002 (later replaced by

EC216/2008):Created EASA.

Established EU requirements for airworthiness, whichwere of mandatory compliance for all Member States(superseded the national rules).

As a consequence, Implementing Rules were created tocover airworthiness, in particular:

Initial Airworthiness (EC1702/2003):

Part-21 for Product Certification, certification of Design

and Production organisations, issuance of Certificatesof Airworthiness, etc.

Certification Specifications (CSs) for productcertification

Continuing Airworthiness (EC2042/2003): Part-M/-145/-66/-147.


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Continuing Airworthiness rules

How the new Implementing Rules for ContinuingAirworthiness were created:

Part-145/-66/-147 were relatively easy: They were basedon similar JAA rules already existing, with the main

difference of introducing Authority Requirements inSection B of each rule.

What about Part-M?


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Why Part-M was necessary?

Part-M was necessary because the Basic Regulation

EC1592/2002, under the Continuing Airworthinessrequirements, covered a much larger range of activities,operations and aircraft categories than the existing JAArules. As a matter of fact:

Part-145 only covered the requirements for the

approval of a maintenance organisation and how thisorganisation performs the maintenance they havebeen ordered by the owner/operator/CAMO.

However, Part-145 did not cover how theairworthiness status of the aircraft is determined,controlled and maintained, how maintenance is

planned and ordered and who is responsible for what.The use of a Part-145 organisation was only required

for large aircraft and aircraft used in Commercial AirTransport. It was too restrictive for non large aircraftand other types of operations.


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What is included in Part-M ?

How the airworthiness status of the aircraft is determined,controlled and maintained, how maintenance is planned andordered and who is responsible for what. (Subpart-M of JAR-OPS1was used as a basis and it was adapted to the different aircraftcategories and operations)

Maintenance standards to be met.

Requirements for maintenance organisations involved in themaintenance of aircraft other than large not used for CommercialAir Transport (Subpart F maintenance organisations). For largeaircraft and aircraft involved in CAT, the requirements are in Part-145.

Requirements for independent certifying staff performing certainmaintenance for aircraft other than large not used for CommercialAir Transport.

Pilot-owner maintenance.

Requirements for the renewal of the validity of the Certificate ofAirworthiness (airworthiness reviews).


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Responsibilities

Main responsibilities of the owner/operator/CAMO:

The owner/operator/CAMO is responsible for theairworthiness of the aircraft and deciding whatmaintenance is needed and when and where it has to beperformed.

The owner/operator/CAMO is responsible for coordinatingmaintenance activities when several maintenanceorganisations are involved.

The owner/operator/CAMO is not responsible for how themaintenance is performed. This is the responsibility of themaintenance organisation (it holds an approval).

However, the owner/operator/CAMO is responsible forverifying that all the maintenance ordered has beencompleted and released, as well as for maintaining thecorresponding records.


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Fundamental aspects of the system

Fundamental aspects of the system:

The system is based on a chain of different approvals:

CAMO (Part-M, Subpart G), Maintenance Organisation(Part-145 or Part-M Subpart-F), Licensed personnel (Part-66), Maintenance Training Organisations (Part-147).

Each approval is under the oversight of a competentauthority.

Adequate communication and exchange of informationbetween competent authorities is essential since there are

different authorities involved:

State of Registry, State of Operator, State of CAMO,State of the Maintenance Organisation, State issuingthe Part-66 licence.


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Fundamental aspects of the system

Fundamental aspects of the system:

The system is based on a chain of oversight activitiesand responsibilities:

The Quality System of the approved organisation.

The oversight performed by the competent authorityissuing the organisation approval.

The oversight performed by the State where theorganisation is located (may be different from theState who issued the approval).

Airworthiness Reviews performed on the aircraft forthe renewal of the Certificate of Airworthiness.

The ACAM (Aircraft Continuing AirworthinessMonitoring) programme of the State of Registry.


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Current simplifications (General Aviation)

Simplification for General Aviation:

Regulation EC1056/2008


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Current simplifications (General Aviation)

See attached table with different

aircraft categories and types ofoperation.


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Future simplifications (General Aviation)

Future simplifications (General

Aviation)


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1429 February 2012 Aviation Conference in Norway (Bodo)27/10/2011 Part-M General Aviation Workshop 14

On-going work

Standard changes and repairs

Opinion 01/2011 (task MDM.032): Currently in theprocess of being adopted by the Commission.

Task MDM.048

Guidance for TBO (Time Between Overhaul)

Task MDM.038

ACAM

Task M.027

Import of aircraft

Task MDM.078


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On-going work

Task MDM.048 CS for standard changes and repairs(similar to AC43-13)

ToR published on 28 July 2011.

Applicable to aeroplanes up to 5700 Kg MTOM, rotorcraft

up to 3175 Kg MTOM, sailplanes , balloons and airships.

To be performed in phases depending on the differentaircraft categories, starting by the smaller ones.

Agency task with support of industry associations.

It is linked to the Opinion issued as a result of taskMDM.032.


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On-going work

Task MDM.038 Guidance on TBO limits

NPA2011-15 published on 16 September 2011 (3 monthconsultation).

Covers all type of components installed on non-powered

and piston engine aircraft other than complex motor-powered aircraft, when not used for Commercial AirTransport.

Very detailed guidance on the inspection procedure toextend the TBO of a piston engine.


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On-going work

Task M.027 Guidance for Aircraft ContinuingAirworthiness Monitoring (ACAM)

NPA2011-19 published on 29 November 2011 (3 monthconsultation).

This task mostly affects NAAs.


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Additional work

The inputs received in the Part-M General Aviation Workshopheld in Cologne on 27 October 2011 gave several avenues forextra work:

Standardisation will put emphasis on the level playing

field Rulemaking needs to review and simplify the rules

EASA needs to work to improve its change management

Stakeholders and NAAs should help EASA translate AMCs

All should work together to reach a commonunderstanding


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Task Force

A taskforce has been created to address the following:

General simplification (Part-M for GA in particular)Handling of modifications

Handling of Parts (certificates required)

Qualifications and privileges of persons

Pilot-owner

Certifying staffPersons carrying out reviews

Other persons

Import/transfer of aircraft

ACAM

Calendar:Launched in December 2011

Action plan by June 2012


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Task Force (immediate action)

In addition, the Agency must take immediate action in the areas

whereHigh costs have been identified

No real safety benefit has been identified

Quick fixes

These areas are the following:Maintenance Programmes

Airworthiness Reviews

Calendar:

Agree within the task force on a fast track processNPA by June 2012

Opinion by end 2012


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CURRENT DISCUSSIONS WITHIN THE TASK FORCE:

Maintenance Programme (MP):Create, with the help of the Industry, Generic MPs (forsailplanes, balloons, etc). Introduce them in AMCmaterial.

Define in the AMC a template for the customized MP:

It will refer to the Generic MP (if available) or to theparticular documents of the manufacturer (it can workby reference or copying the specific tasks).

It will contain the applicable information specific forthe particular aircraft (maintenance linked to STCs,

modifications, ADs, life limited parts, pilot-ownermaintenance, etc.

Emphasize the possibility for indirect approval procedure.

Annual review of MP at the time of Airworthiness Review.


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2229 February 2012 Aviation Conference in Norway (Bodo)27/10/2011 Part M General Aviation Workshop 22


CURRENT DISCUSSIONS WITHIN THE TASK FORCE:

Airworthiness Review (AR):Initial discussion focused on ELA aircraft not used incommercial operations.

AR to be performed at the same time as the annualinspection.

AR to be performed by Airworthiness Review Staffnominated by the maintenance organization (no need toinvolve a CAMO or the NAA). Maintain also the option thatthe AR is performed by a CAMO or the NAA.

Allow that the person performing the annual inspection is

the same as the one performing the Airworthiness Review(no need for independence).

what+is+easa+part m+continuing+airworthiness

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