1

Airworthiness Policy Update

Tim Drinkwater

13 February 2018

2

Topics for today

▪Rulemaking update for Part 145 & related

Part M

▪MOR update

▪Please ask questions as we go?

3

Rulemaking – future changes (green)

Commission Regulation (EU) No 1321/2014

Annex I Part-MAnnex II Part-145

Annex III Part-66Annex IV Part-

147Annex Va Part-T Annex Vb –

Part-ML

Annex Vc

Part-CAMO

Annex Vd

Part-CAO

Cover Regulation

4

Rulemaking

▪ Part M Light

▪ Part CAMO (SMS)

▪ Part CAO

▪ Agreement by the Member States on the proposed text

▪ Review by the Legal Services of the Commission before vote by the Member States

▪ Still ongoing due to issues raised by the Commission Legal Services

▪ No visibility of when the text could be finally voted by the Member States

▪ Not expected to be in force until early 2019

5

Part T

▪From 25 Sept 2017

▪Part T approval required for the management of

third country aircraft leased in by a European

AOC holder

▪The CAMO will need to have their (Part T)

procedures approved before an AOC holder can

lease in an aircraft

6

Part 145 change for Contracts

CAMO Contracts Part 145

when the CAMO is not appropriately approved to Part 145, the

organisation shall in consultation with the operator, establish a written

maintenance contract with a Part-145

7

Sub-contracting

▪ Allows an unapproved organisation to carry out work under the Quality system of an Approved Maintenance Organisation

▪ Provides for specialised processes to be sub-contracted

▪ Such as painting – is it a specialised process?

8

GR 10 Painting Revision July 17

▪ The task of painting an aircraft or making a change to its surface finish,such as paint removal and subsequent polishing, is a maintenance taskand consequently a CRS must be issued upon completion of theprocess.

▪ Simple repairs & minor touch up is considered line maintenancewhen conditions are appropriate

▪ A complex type must be controlled by an MRO that includes that type ontheir approval

▪ That MRO then paints the aircraft in its own painting facilities withapproval for the type and issues the CRS

▪ The most straight forward way – via a contract with the CAMO

9

Painting

ContractCAMO Part 145

10

GR10 Painting continued

▪ When the Contracted 145 does not have an approved facility

to paint the specific aircraft type

▪ It sub contracts the painting task to an aircraft paint facility in

accordance with approved procedures

▪ As with all sub contracting the Part 145 MRO retains

responsibility for all work performed, that includes

▪ Facilities

▪ Tooling

▪ Equipment

▪ Data

▪ Competence of all staff involved in and overseeing the

paint task

11

Painting

12

GR 10 - Finally

▪ Specialist painting organisations are not entitled to issue

any certification in respect of the airworthiness status of an

aircraft following painting, unless the organisation also holds

an appropriate ‘A’ rated maintenance organisation approval.

13

Terminology/Changes in Part M/145

▪ A refresher on terms used now

▪ Licensed Air Carrier

▪ Complex Aircraft

▪ Part 145.A.48 addition with lots of AMC

▪ Critical Maintenance Tasks

▪ Identical Maintenance Tasks

▪ Tool Control

▪ Extraneous Material

14

Occasional & Temporary Line Stations

– IN-2017/011

▪ Occasional – infrequent or irregular, of limited duration

▪ Limited to 10 consecutive days

▪ Does not include scheduled maintenance

▪ Process and procedures required

▪ Temporary

▪ Organisation audits prior to start

▪ CAA notified via SRG 1761 on website

▪ Process and procedures required

▪ In operation for a maximum of 6 months

▪ More than 6 months – permanent line station required

▪ Repetitive use at same location not permitted

15

Apply on the Website

16

SRG 1761 - for Line Station Change

17

Rulemaking – update on 376/2014

Commission Regulation (EU) No 1321/2014

Annex I Part-M

Annex II Part-145

Annex III Part-66

Annex IV Part-147

Annex Va Part-T

Annex Vb -Part-ML

Annex Vc Part-CAMO

Annex VdPart-CAO

(EC) 216 ‘BASIC’ REGULATION

Cover Regulation

(EU) 376/2014

Commission Implementing Regulation (EU) 2015/1018

18

376 and 216 – Currently ‘Parallel’

216/2008

Part 145

AMC

376/2014

IR 2015 1018

Guidance

19

Future Changes

20

CAA Auditing of 376/2014 starts 2018

Compliance Checklist Available

21

Civil Aviation Authority Guidance

22

CAP 1496 ECCAIRS Guidance

23

Help from Europe

24

Help from Europe 2

25

Guidance – not from EASA

26

Help from Europe 3

27

Changes to the MOR System

▪ Audit will look for more than just a reference to 376/2014 and

ECCAIRS to comply

▪ 2015/1018 lists what to report for which sector (see flyer)

▪ Annex II of 2015/1018 relates to Technical Conditions, Maintenance

and the Repair of the Aircraft

▪ Design and Manufacture

▪ 18 items - Includes Life items not reaching their life limit

▪ 376 includes additional time limits regarding Safety Related items

▪ For Part 145 – not such a substantial change – 376 also includes

Voluntary Occurrence Reporting and Just Culture

▪ Confidentiality in accordance with National Law

▪ Analysis of both types of Report is required

28

Timescales and Decisions

29

Questions

&

Thank you