FLORIDA MODIFICATION SPECIALISTS, LLC SECTION: INTR O … · The Maintenance Annex agreed to by the...

FLORIDA MODIFICATION SPECIALISTS, LLC (FMS) SECTION: INTRO REPAIR STATION QUALITY CONTROL MANUAL PAGE: 1 REPAIR STATION NUMBER 3FMR327B DATE: 06/29/09 REV: 01

FLORIDA MODIFICATION SPECIALISTS, LLC (FMS)

EASA SUPPLEMENT REFERENCE NO. 145.6282

To FAA 14 CFR part 145 Repair Station Manual / Quality Control Manual Reference No.: 06

3430 Flightline Drive

Lakeland, Florida 33811

FAA Repair Station Number 3FMR327B

This supplement does not form part of the FAA 14 CFR part 145 RSM/QCM. Compliance with the FAA accepted supplement together with the FAA 14 CFR part 145 RSM/QCM forms the basis of the European Aviation Safety Agency (EASA) Part-145 approval. This supplement forms part of the applicant’s (FMS) obligations for EASA Part-145 approval as specified in Change 5 of the Maintenance Annex Guidance (MAG).

FLORIDA MODIFICATION SPECIALISTS, LLC (FMS) SECTION: MAIN EASA SUPPLEMENT PAGE: 2 REPAIR STATION NUMBER 3FMR327B DATE: 07/10/12 EASA.145.6282 REV: 02

RECORD OF REVISIONS

MANUAL NO.: 06 MANUAL HOLDER: FMS Intranet Server Retain this record in the manual. Upon receipt of revisions, insert the revised page(s) in the manual and remove the replaced pages (if/as applicable). Enter the insertion date and initials of the person incorporating the revision in the appropriate block on the Record of Revisions. Return the Revision Notice/Acknowledgment (Form TL-0003) to the Chief Inspector.

REVISION NO. REVISION DATE INSERTION DATE BY

Original 05/17/2010 05/17/2010 TJ

01 08/15/2011 08/15/2011

02 07/10/2012 07/10/2012

03 06/20/2013 06/20/2013

04 02/15/2014 02/15/2014

05 03/24/2014 03/24/2014

06 11/12/2015 11/12/2015

FLORIDA MODIFICATION SPECIALISTS, LLC (FMS) SECTION: MAINEASA SUPPLEMENT PAGE: 3 REPAIR STATION NUMBER 3FMR327B DATE: 11/12/15 EASA.145.6282 REV: 06

A. INDEX Page

Manual Identification Cover Page .................................................................................................. 1

Record of Revisions ........................................................................................................................ 2

A. Index .......................................................................................................................................... 3

1. List of Effective Pages .............................................................................................................. 4

2. Amendment Procedure ............................................................................................................. 5

3. Introduction ................................................................................................................................ 5

4. Accountable Manager’s Commitment Statement ................................................................... .5

5. Approval Basis and Limitation .................................................................................................. 6

6. Access by EASA and FAA ........................................................................................................ 6

7. Work Orders / Contracts .................................................................................................. 7

8. Approved Design and Repair Data ................................................................................... 7

9. Airworthiness Directives .......................................................................................................... 10

10. Release and Acceptance of Components ........................................................................... 10

11. Certificate of Airworthiness (C of A) Validity ........................................................................... 16

12 Release of Aircraft After Maintenance .................................................................................... 16

13. Reporting of Unairworthy Conditions ...................................................................................... 17

14 Quality Assurance System (QAS) .......................................................................................... 18

15. Provision of Hangar Space for Aircraft Maintenance ............................................................. 21

16 Contracted Maintenance ......................................................................................................... 21

17. Human Factors ....................................................................................................................... 24

18 Air Carrier Line Stations .......................................................................................................... 24

19. Work Away From Fixed Location ........................................................................................... 25

Appendix I (FAA Form 8130-3) ..................................................................................................... .1

Appendix II (EASA Audit Checklist) ................................................................................................ 1


1. LIST OF EFFECTIVE PAGES

Section Page Rev No. Date EASA Manual ID Cover Page 1 06 11/12/15 Record of Revisions Page 2 02 07/10/12 Index 3 06 11/12/15 List of Effective Pages 4 06 11/12/15 Main - numbered paragraphs 5 06 11/12/15 1 through 19 6 06 11/12/15 7 06 11/12/15 8 06 11/12/15 9 06 11/12/15 10 06 11/12/15 11 06 11/12/15 12 06 11/12/15 13 06 11/12/15 14 06 11/12/15 15 06 11/12/15 16 06 11/12/15 17 06 11/12/15 18 06 11/12/15 19 06 11/12/15 20 06 11/12/15 21 06 11/12/15 22 06 11/12/15 23 06 11/12/15 24 06 11/12/15 25 06 11/12/15 26 06 11/12/15 Appendix I 1 05 03/24/14 2 05 03/24/14 3 05 03/24/14 4 05 03/24/14 5 05 03/24/14 6 05 03/24/14 7 05 03/24/14 Appendix II 1 02 07/10/12 2 02 07/10/12 3 02 07/10/12

Approved by: Donald E. Bruce Signature: Title: CEO / Accountable Manager Date: November 12, 2015-


2. AMENDMENT PROCEDURE

A. The FMS Chief Inspector or his/her designee will prepare amendments to this supplement as required and provide to the FMS CEO/Accountable Manager for his/her approval. Amendments will be submitted to the FSDO for acceptance by the Chief Inspector or his/her designee.

B. For revision and control of this supplement, FMS will apply the same procedures utilized

for controlling and revising the FMS Repair Station Manual (reference Section I of the FMS Repair Station Manual).

C. Failure to ensure that the 14 CFR part 145 RSM/QCM and this EASA Supplement are kept up to date in respect of regulatory changes and that FMS repair station staff comply with the procedures herein could invalidate the EASA Approval.

D. Changes to the MAG shall be implemented, as applicable, within 90 days after the change has been published, unless otherwise specified.

3. INTRODUCTION

A. This section addresses why this supplement is necessary. EASA Part-145 is a European requirement similar to 14 CFR part 145.

B. The Maintenance Annex agreed to by the FAA and EASA specifies the basic differences

between EASA Part-145 and 14 CFR part 145 and identifies these differences as special conditions.

C. A 14 CFR part 145 repair station can be EASA Part-145 approved when the repair station

complies with the maintenance special conditions as detailed in this procedure in addition to complying with 14 CFR parts 145 and 43.

D. This supplement is intended to ensure FMS is working in accordance with the provisions

of the EASA Part-145 Approval Certificate and to ensure that the differences between the EASA and FAA regulations are taken into account.

4. ACCOUNTABLE MANAGER'S COMMITMENT STATEMENT

A. This supplement in conjunction with the accepted 14 CFR part 145 RSM/QCM reference number 06 defines the FMS organization and procedures upon which EASA approval is based.

B. These procedures are approved by the undersigned, and must be adhered to, as

applicable, when maintenance work/orders are being performed under the conditions of the EASA Part-145 approval.


C. It is accepted that the repair station’s procedures do not override the necessity of complying with any additional requirements formally published by the EASA and notified to this organization from time to time.

D. It is understood that the EASA shall issue an Approval Certificate and list this repair

station in an EASA published list as long as the EASA is satisfied that the procedures are being followed and work standards maintained. It is further understood that EASA reserves the right to revoke the Approval Certificate if EASA considers that procedures are not followed or standards not upheld. Commitment Statement signed by the Accountable Manager for and on behalf of the repair station:

November 12, 2015 Donald E. Bruce Date CEO / Accountable Manager

NOTE: If/when the FMS Accountable Manager is replaced, the new Accountable

Manager must sign the statement to ensure continuous EASA Part-145 Approval and provide the responsible ASI with the amendment of the supplement.

5. APPROVAL BASIS AND LIMITATION

A. EASA approval is based upon compliance with 14 CFR Parts 145 and 43 except where varied by the special conditions specified in the Maintenance Annex and associated guidance. However, this approval must not exceed the ratings permitted by Commission Regulation (EC) No. 1321/2014.

B. The approval of maintenance activities is limited to the scope of work permitted under the

current certificate issued by the FAA to FMS in accordance with 14 CFR part 145 for work carried out within the United States. Deviations have to be agreed on a case-by-case basis by the JMCB.

6. ACCESS BY EASA AND FAA

A. In accordance with the MAG Agreement, Annex 2, Appendix 1, paragraph 1.2:

(1) The FMS CEO / Accountable Manager confirms that FMS agrees to provide access to EASA and FAA to ascertain compliance with 14 CFR part 145, the EASA Special Conditions, procedures and standards and to investigate specific problems.


(2) The FMS CEO / Accountable Manager confirms that FMS will accept investigation and enforcement action that may be taken by EASA in accordance with any relevant EU regulations and EASA procedures and that FMS will cooperate with these actions.

7. WORK ORDERS / CONTRACTS

A. Prior to conducting maintenance activities, FMS will first obtain a Work Order / Contract (i.e. Service Order) from the customer (reference Section I of the QCM regarding Service Orders).

B. The Service Order will be used to describe the scope of work to be accomplished for the

customer. Service Orders will annotate the details, specify the inspections, repairs, alterations, overhaul, airworthiness directives and parts replacements that are to be carried out.

C. The Director of Maintenance or his/her designee is responsible to communicate with the

customer for any workscope or other situation that requires specific clarification or interpretation, or should any doubt exist of understanding to ensure completeness of and compliance with the customers’ Service Order. The Director of Maintenance will involve as necessary the Chief Inspector for issues concerning inspection and/or other quality matters.

D. The customer remains responsible for correctly informing FMS through the Service Order

of all required maintenance and alterations. 8. APPROVED DESIGN AND REPAIR DATA

A. Changes to the type design: Major Changes, Minor Changes, STCs.

(1) The EASA-approved design engineering data is normally data supplied by an EASA Design Organization Approval (DOA) holder, or data approved by the National Aviation Authority of the Type Certificate Holder (or equivalent), or data supplied by the customer and approved by the EASA. In all cases, the customer is responsible for confirmation of data approval. Details for the acceptance and/or validation of FAA approved changes to the type design by EASA are contained in Annex 1 to the Agreement and in the Technical Implementation Procedures (TIP).

NOTE: EASA defines “design change” as a change to the type design. EASA does

not automatically accept alterations that affect type design.


B. Repairs:

(1) FAA shall approve design data in support of major repairs in accordance with FAA Order 8110.4, Type Certification; FAA Order 8110.37, Designated Engineering Representative Guidance Handbook; FAA Order 8100.15, Organization Designation Authorization Procedures; and FAA Order 8900.1, Flight Standards Information Management System. Minor repairs are made in accordance with “acceptable” data, in accordance with 14 CFR part 43.

(2) EASA shall approve design data in support of repairs in accordance with EASA Part

21 Subpart M-Repairs and EASA’s procedure Type Certificate Change and Repair Approval.

C. EASA Acceptance of FAA Repair Design Data.

(1) Non-Critical Components

a. EASA shall accept data used in support of major repairs regardless of the State of Design of the product, part or appliance, if:

i. EASA has certificated/validated the product or appliance, ii. The FAA is the authority of the State of Design for the repair design data, and

iii. The FAA repair design data approval is substantiated via an FAA letter or

FAA Form 8110-3, FAA Form 8100-9, properly executed FAA Form 337, or a signed cover page of a repair specification.

b. EASA shall also accept data used in support of minor repairs when:

i. EASA has certificated/validated the product or appliance, ii. The FAA is the authority of the State of Design for the repair design data, and

iii. The repair design data has been provided by a U.S. TC/STC or TSOA holder,

or

iv. For minor repairs from other than a U.S. TC/STC or TSOA holder, the determination that data is acceptable (under 14 CFR Part 43) has been made by a U.S. maintenance organization under the FAA’s authorized system.


NOTE: An EU company must use EASA Part 21 for the approval of repair data for use on an EU-registered aircraft. Unless the minor repair data has been previously used on an N-registered aircraft, an EU company cannot determine any data to be acceptable data under 14 CFR Part 43 for use on an EU-registered aircraft.

c. In these circumstances, repair design data is considered to be EASA approved

following its approval or acceptance under the FAA’s system. This process does not require application to EASA or compliance findings to the EASA certification basis.

(2) Critical Components

NOTE: A critical component is defined as a part identified as critical by the design approval holder during the validation process, or otherwise by the exporting authority. Typically, such components include parts for which a replacement time, inspection interval, or related procedure is specified in the Airworthiness Limitations section or certification maintenance requirements of the manufacturer’s maintenance manual or Instructions for Continued Airworthiness.

a. EASA shall accept any critical component repair design data from a TC/STC

holder, regardless of the State of Design of the product, if:

i. EASA has certificated/validated the product, and ii. The FAA is the authority of the State of Design for the repair design data.

iii. In these circumstances, repair design data is considered to be EASA

approved following its approval under the FAA’s system. This process does not require application to EASA or compliance findings to the EASA certification basis.

b. Repair design data on critical components, developed by organizations/persons

that are not the TC/STC Holder, shall be submitted to the Agency for approval following the standard application procedure, with an EASA Form 31. Applicants do not need to hold a DOA if the repair data has been approved by the FAA.


9. AIRWORTHINESS DIRECTIVES

A. The customer will notify FMS of any EASA Airworthiness Directives (AD’s) they request accomplished during performance of their particular workscope during preparation of the Service Order (reference Section I of the QCM regarding Service Orders).

B. It is the responsibility of the customer to supply all applicable EASA Airworthiness

Directives (AD’s) to FMS. NOTE: EASA provides an electronic repository of Airworthiness Directives via Internet

access at:

http://ad.easa.europa.eu/

C. The Lead is responsible to assign and ensure AD’s reflected on the customer Service Order are accomplished during the customer’s workscope.

D. FMS will retain a copy of all Airworthiness Directives the customer requires accomplished

in the closed records package (reference Section X of the RSM regarding Records and Record Keeping).

E. If FMS is unable to fully comply with an applicable Airworthiness Directive, its non-compliance will be recorded in the item’s maintenance records. Additionally, the Chief Inspector or his/her designee will notify the respective customer representative and advise accordingly.

10. RELEASE AND ACCEPTANCE OF COMPONENTS

A. This section describes the procedures FMS will use to ensure that the Release to service of components up to and including complete powerplants will be carried out in accordance with 14 CFR § 43.9, except that paragraphs 7 through 10 shall also be taken into account. At the completion of maintenance, an FAA Form 8130-3 shall be issued as a maintenance release by the repair station.

B. The FAA Form 8130-3 should include the EASA Part-145 release to service certifying

statement with the EASA Part-145 Approval Certificate number in block 12, and specify any overhaul, repairs, alterations, Airworthiness Directives, replacement parts, PMA parts and quote the reference and issue/revision of the approved data used.

C. Instructions including a completed example of an FAA Form 8130-3 dual release is located in Appendix I of this supplement. NOTE: Blocks 13a through 13e of an FAA Form 8130-3 are not to be used by FMS.


D. The signature of the person returning the component to service shall be in block 14b with FMS’s FAA Repair Station Certificate number in block 14c.

E. The status of the component (repaired, inspected, overhauled, etc.) shall appear in block

11 with any relevant comments including detailed references to approved data, ADs, etc., in block 12. Example: “Overhauled in accordance with CMM 111, Section X, Rev 2, S/B 23 and FAA AD xyz complied with. Full details held on WO 456.”

F. Block 12 shall also contain the following statement: “Certifies that the work specified in block 11/12 was carried out in accordance with EASA Part-145 and in respect to that work the component is considered ready for release to service under EASA Part-145 Approval Number: “EASA 145…….” NOTE: In the case of maintenance carried out by a U.S.-based EASA Part-145 approved

organization subject to the Agreement, EASA only recognizes the dual release FAA Form 8130-3 for component, engine, or propeller maintenance.

G. The sub clause “except as otherwise specified” is intended for use with two types of

deviations as follows:

(1) The case where all required maintenance was not carried out. In this case, list the maintenance not carried out in Block 12 and/or attachments.

(2) The case where the particular maintenance requirement was only EASA-approved

and not FAA-approved. Example: an EASA Airworthiness Directive not approved by the FAA.

H. Section III of the FMS RSM pertains to the FMS Roster of Management, Supervisory, and

Authorized Inspection Personnel (Form QA-0041) including how it is maintained and revised. FMS Form QA-0041 identifies personnel authorized to sign an FAA Form 8130-3 (maintenance release) for approving a maintained or altered article for return to service.

I. The following provides information regarding the acceptability of components authorized

for use during maintenance. NOTE: Component means any component part of an aircraft up to and including a

complete powerplant and any operational or emergency equipment. (1) Only the following new and used components may be fitted during maintenance.


a. New Components.

i. New components must be traceable to the OEM as specified in the Type Certificate (TC) holder’s Parts Catalogue and be in a satisfactory condition for installation. A release document issued by the OEM or Production Certificate (PC) holder must accompany the new component. The release document must clearly state that it is issued under the approval of the relevant AA under whose regulatory control the OEM or PC holder works.

ii. For U.S. OEMs and PC holders, release must be on the FAA Form 8130-3

as a new part. iii. For all EU Member States, OEMs, and PC holders, release must be in

accordance with EASA Part-21 on EASA Form 1 as a new part.

iv. For Canadian OEMs and PC holders release must be on the Canadian Form One as a new part.

v. Standard parts are exempt from the forgoing provisions, except that such

parts must be accompanied by a conformity statement and be in a satisfactory condition for installation.

NOTE: EASA Standard Parts Definition: Per AMC M.A.501(c), “Standard

Parts are: parts manufactured in complete compliance with an established industry, Agency, competent authority or other Government specification which includes design, manufacturing, test and acceptance criteria, and uniform identification requirements. The specification should include all information necessary to produce and verify conformity of the part. It should be published so that any party may manufacture the part. Examples of specifications are National Aerospace Standards (NAS), Army-Navy Aeronautical Standard (AN), Society of Automotive Engineers (SAE), SAE Sematec, Joint Electron Device Engineering Council, Joint Electron Tube Engineering Council, and American National Standards Institute (ANSI), EN Specifications etc…”

vi. PMA parts may only be accepted as detailed in EASA Part-21 or in Annex 1

of the Agreement. vii. Engines rebuilt by the production approval holder can be accepted as

specified in the Technical Implementation Procedures for Airworthiness and Environmental Certification (TIP- paragraph 5.1.4).


b. Used Components

i. Used components shall be traceable to AMO’s and/or repair stations approved by the authority who certified the previous maintenance, and in the case of life limited parts, certified the life used. The used component must be in a satisfactory condition for installation and be eligible for installation as stated in the TC holders Parts Catalogue.

ii. An FAA Form 8130-3 issued as a dual maintenance release must accompany

used components from EASA-approved U.S.-based 14 CFR part 145 repair stations.

iii. Used components from a 14 CFR part 145 repair station not EASA-approved

must not be used even if accompanied by an FAA Form 8130-3.

iv. An EASA Form 1 issued as a maintenance release shall accompany used components from EASA Part-145 approved maintenance organizations not located in the U.S.

v. A Canadian Form One issued as a maintenance release must accompany

used components from a Canadian EASA-approved maintenance organization.

NOTE: Canadian EASA-approved maintenance organizations will specify

the EASA release statement and their EASA approval number in the remarks block of Canadian Form One.

vi. Used components that have been issued a triple release (i.e., certifying

compliance with FAA, EASA, TCCA requirements) on an EASA Form 1 as a maintenance release are acceptable.

Remainder of page purposely left blank.


J. The following table is a summary of possible cases:

* For the purpose of the table above, triple release mentioned in subparagraph vi. above

has the same status as EASA Form 1 Dual.

Privileges of the dual EASA and FAA certificated maintenance organization

United States Europe

Release Document of Final Assembly: 8130-3 Dual Release

Release Document of Final Assembly: EASA Form 1 Dual Release

Acceptable New Products/Articles: EASA Form 1 NEW 8130-3 NEW C of C Standard Parts

Acceptable New Components: EASA Form 1 NEW 8130-3 NEW C of C Standard Parts

USED Products/Articles: Acceptable Used Products/Articles Release Document (input)

Final Assembly Release document

(output)

USED Components: Acceptable Used Components Release Document (input)

Final Assembly Release document (output)

8130-3 Single 8130-3 Single Form 1 Single Form 1 Single 8130-3 Dual 8130-3 Dual Form 1 Dual* Form 1 Dual* Form 1 Dual* 8130-3 Dual 8130 Dual Form 1 Dual* Form 1 Single Form 8130-3

(See below U.S.)

8130-3 Single Form 1 (see below Europe)


United States

One or more products/articles were installed with an EASA Form 1 single release and so the final assembly cannot be released with an 8130-3 dual release. The final release should be issued with the following statements in the specified blocks. “The final assembly is eligible to be installed only on an EU registered aircraft.”

In block 14a only check the box mentioning “Other regulation specified in block 12.” Do not check box that states compliance to § 43.9.

In block 12, the following text should be inserted:

“Certifies that the work specified in Block 11/12 was carried out in accordance with EASA Part 145 and in respect to that work the component is considered ready for release to service under EASA Part 145 approval no.: EASA.145.6282.

This product/article meets part § 43.9 requirements, except for the following items, and therefore is not eligible to be installed on U.S.-registered aircraft:”

(List the items)

Europe

One or more products/articles were installed with a FAA Form single release and so the final assembly cannot be released with an EASA Form 1 dual release. The final release should be issued with the following statements in the specified blocks. “The final assembly is eligible to be installed only on an US registered aircraft.”

In block 14a, check only the box mentioning “Other regulation specified in block 12.” Do not check the box that states compliance to 145.A.50.

In block 12, include the following release statement:

“The work identified in Block 11 and described herein has been accomplished in accordance with 14 CFR Part 43 and in respect to that work; the items are approved for return to service under certificate no._______.”

This product/article meets 145.A.50 requirements, except for the following items, and therefore is not eligible to be installed on an EU-registered aircraft:”

(List the items)


11. CERTIFICATE OF AIRWORTHINESS (C of A) VALIDITY

A. This section describes the procedures FMS will use to ensure that the Certificate of Airworthiness and the Airworthiness Review Certificate are valid prior to the issue of a release to service document.

NOTE: EU aircraft have indefinite C of As, the C of A’s validity period is verified by means

of an “Airworthiness Review Certificate” (ARC). The EASA Operator or owner is responsible for ensuring the C of A remains valid but the repair station should ensure that the ARC has not expired prior to release of the aircraft as specified in Section B Appendix 1 paragraph 12. If the ARC has expired, inform the customer prior to the release as specified in paragraph 12.

12. RELEASE OF AIRCRAFT AFTER MAINTENANCE

A. This section describes the procedures FMS will use to ensure that the Release to service of aircraft will be carried out in accordance with 14 CFR § 43.9 except that paragraphs 7 through 10 and 12 of this supplement must be taken into account.

B. At the completion of maintenance, FMS will make the following certification in the aircraft

maintenance record. C. Return to Service in Accordance with 14 CFR § 43.9 and the following:

“Certifies that the work specified; except as otherwise specified, was carried out in accordance with FAA airworthiness regulations, and in respect to that work the aircraft is considered ready for release to service.”

D. The sub clause “except as otherwise specified” is intended for use with two types of deviations as follows:

(1) The case where all required maintenance was not carried out. In this case, list the

maintenance not carried out on the 14 CFR § 43.9 Return to Service and/or attachments.

(2) The case where the particular maintenance requirement was only EASA-approved

and not FAA-approved. Example: an EASA Airworthiness Directive not approved by the FAA.

E. Where the customer or operator requires his/her paperwork to be signed, the following

alternate certification can be made.


(1) Release to Service in Accordance with EASA Part-145.A.50:

“Certifies that the work specified, except as otherwise specified, was carried out in accordance with EASA Part-145 and in respect to that work the aircraft is considered ready for release to service.”

(2) In all cases, FMS will issue the certification when all required maintenance has been

carried out, except that if it was not possible to complete all maintenance actions requested, then details of the work not performed must be endorsed on the Release to Service and the Operator informed.

(3) FMS will enter the EASA Part-145 Approval Certificate Number 145.6282 and the FAA

14 CFR part 145 Certificate Number 3FMR327B in all cases, whether it is a 14 CFR part 43 Return to Service or an EASA Part-145 Release to Service.

13. REPORTING OF UNAIRWORTHY CONDITIONS

A. This section describes the procedures FMS will use to ensure that, when serious defects are found in EU-registered aircraft or components received from an EU customer, the defects are reported to EASA, the aircraft/component design organization, and the customer or Operator within 72 hours. When reporting to the EASA, the identity of the customer must be included to allow follow up action.

B. The FMS Chief Inspector or his/her designee will submit a report in a form and manner

acceptable to EASA containing the information required by EASA Part-145 in English through: (1) EASA online platform (2) Occurrence Reporting Form

(3) FAA Service Difficulty Report, or

(4) FAA SUP report

NOTE: FAA Service Difficulty Report is addressed in Section VII of the FMS QCM.


C. The FMS Chief Inspector or his/her designee will submit this form in accordance with the timeframe specified in EASA Part-145, when reportable problems are found on an aircraft, power plant, propeller, or component thereof that is subject to the regulatory control of EASA. NOTE: EASA Part-145 occurrence reporting requirements include SUP reporting

requirements

D. The Chief Inspector or his/her designee shall be responsible for the reporting of Suspected Unapproved Part (SUPS) (reference Section III of the FMS QCM).

14. QUALITY ASSURANCE SYSTEM (QAS)

A. This section describes the detailed procedures FMS will use for the operation of an independent QAS.

B. The primary objective of the QAS is to enable the organization to satisfy itself that it can

deliver a safe product and that it remains in compliance with 14 CFR part 43, 14 CFR part 145, and the EASA Special conditions.

C. The FMS CEO / Accountable Manager is responsible to ensure compliance with and the effectiveness of the QAS.

D. The Chief Inspector is responsible for developing an audit plan annually that includes applicable paragraphs of 14 CFR part 43 and part 145 and the EASA special conditions including assigning audits and analyzing their results.

E. The QAS should include all the contracted work in accordance with guidance given in item 16 of this Supplement.

F. There are two elements to the system: (1) An independent audit system.

a. The independent audit system is a process of sample audits of all aspects of the repair station’s ability to carry out all maintenance to the required standards. It represents an overview of the complete maintenance system and does not replace the need for mechanics to ensure that they carry out maintenance to the required standard nor does it replace any associated inspection/quality control system. Independence shall be established by ensuring that audits are not carried out by the personnel responsible for the function, procedure, or product being audited.


b. The audit system shall cover the oversight of all multiple facilities and line stations under the approval and must contain as a minimum the following:

i. Procedural audits. The audits should monitor compliance with required

aircraft/aircraft component standards and adequacy of the maintenance procedures to ensure that such procedures invoke good maintenance practices and airworthy aircraft/aircraft components.

ii. Product audits. The sample check of a product means to witness any relevant

testing and visually inspect the product and associated documentation. The sample check should not involve repeat disassembly or testing unless the sample check identifies findings requiring such action.

c. It is acceptable to use personnel from one section/department to audit the work

and products of another section/department in accordance with a procedure under this section, which defines the audit program.

d. The process of sample audits may be carried out once per year as a single

exercise or conducted in segments during a period of one year in accordance with the audit program contained in this Supplement. All applicable 14 CFR parts 43 and 145 provisions and the EASA Special Conditions as detailed in this guidance should be checked at least once per year against each primary product line.

e. A primary product line is any one aircraft, engine, avionic, or mechanical product

line where the systems and procedures are very similar throughout that product line.

f. Repair stations with fewer than 10 employees may contract the audit function to a

person acceptable to EASA who is not employed by the repair station. But in this case the audit of all applicable 14 CFR parts 43 and 145 provisions and EASA Special Conditions as detailed in this guidance must be carried out twice per year.

(2) A management/control and follow up system.

a. The management control follow up system, which must not be contracted to outside persons, consists of a system to ensure that all findings/discrepancies resulting from the independent audit system are corrected in a timely manner and to enable the accountable manager to remain informed of the state of compliance and any safety issues. The accountable manager should hold routine meetings to check the progress on clearing outstanding findings/discrepancies, except that in the larger repair stations such meetings may be delegated on a day-to-day basis to the Quality Manager as long as the accountable manager meets at least once per year with the senior staff involved to review the overall performance.


b. Where the repair station has associated line stations and/or additional fixed locations, the system should describe how these are integrated into the system and shall specify the need to audit each line station and/or additional fixed location at least once per year.

c. Where applicable, each line station that is used by an aircraft operated under the

regulatory control of an EU Operator in accordance with the conditions of the Maintenance Annex should be listed giving its location and the basic maintenance capability at each such location.

d. The QAS as specified in this section must be extended to include the need for the

approved maintenance organization to audit the listed line station and/or additional fixed locations.

e. One example of the particular product line shall be used as the basis of each audit,

except in the case of stores audits when a random selection of parts should be used for the audit. It therefore follows that a repair station maintaining aircraft and engines (off aircraft) and mechanical parts (off aircraft) would need to carry out three audit sample checks each year with the particular product type changed each year. A sample audit program is attached (see Appendix II of this Supplement).

f. A report shall be prepared for each audit carried out describing what was checked

and any resulting findings/discrepancies. The report should be sent to the relevant departments for rectification action giving target rectification dates. The relevant departments are required to rectify the findings/discrepancies and inform the quality department.

g. Discrepancies will be recorded on FMS Corrective Action Request (CAR) FMS

Form QA-0045, and the process in QCM, Section IX, paragraph 2. applied.

h. A product should be selected in each hangar and each workshop and the sample audit program conducted at least once per year (twice per year in the case of a repair station with fewer than 10 employees and which chooses to contract the audit to an outside person except that in the case of procedures which are common throughout the repair station, the procedures need only be audited once per year if there are no problems).

(3) An example EASA Audit Checklist plan is located in Appendix II of this Supplement.

The EASA Audit Checklist is derived from the MAG provides the elements that must be audited. It is intended that the EASA Audit Checklist plan is used in conjunction with FMS Internal Audit Checklist (Form QA-0009).


(4) The Chief Inspector will retain a copy of the EASA Audit Checklist, FMS Internal Audit Checklist (Form QA-0009), narrative report, and any other associate audit documents. NOTE: Also refer to the FMS QCM, Section IX pertaining to Audit and Corrective

Action. 15. PROVISION OF HANGAR SPACE FOR AIRCRAFT MAINTENANCE

A. This section described the procedures FMS will use to ensure that covered hangar space is available for the Base maintenance of aircraft operated under the regulatory control of an EU Member State undergoing maintenance and/or alteration.

B. The FMS CEO / Accountable Manager is responsible to ensure that when the customer

and FMS sign a contract for maintenance, the agreement confirms that hangar space will be available at the time of maintenance and alterations.

C. The Director of Maintenance or his/her designee is responsible to ensure the provision of covered hangar space is provided while Base maintenance of aircraft operated under the regulatory control of an EU Member State is undergoing maintenance and/or alteration. NOTE: The RSM Section IV, paragraph 3. provides a description of the FMS Housing

and Facilities. 16. CONTRACTED MAINTENANCE

A. This section describes the procedures FMS will use to ensure that the items to be contracted are specified and that the contract meets the terms of the implementation procedures.

NOTE: Refer FMS RSM, Section IX regarding Contract Maintenance.

B. When part of the maintenance is contracted to another organization, FMS shall ensure

that the other organization is approved to EASA Part-145 for the maintenance they carry out (contracting).

(1) If maintenance is contracted to a non-EASA-approved organization (subcontracting),

then this is considered to be a Non–certificated Facility. In such a case, FMS is fully responsible for ensuring its airworthiness.


C. List of Contractors (1) EASA recognizes 14 CFR part 145 requirements for the Repair Station Manual to

contain a list of all contractors utilized by the Repair Station and approved by the FAA as part of the Repair Station Manual.

(2) FMS Master Vendor/Contractor List (Form QA-0027) is used as an all-inclusive listing

to easily identify the authorized vendors that FMS utilizes to provide services and/or materials to FMS, including certificated and noncertificated contractors. FMS Form QA-0027 also records certificate type and ratings as applicable.

(3) FMS Forms QA-0035 (FMS Supplier/Vendor/Agency Audit Questionnaire) and

QA-0036 (FMS Supplier Vendor (145) Audit Checklist/Questionnaire) are used in conjunction with Form QA-0027. Section A. 2. of Form QA-0036 specifically records certifications including contractors who hold an EASA 145 certificate.

(4) FMS shall make FMS Forms QA-0027, QA-0035, and QA-0036 available to EASA on

request. D. Qualifying and Auditing Contractor

(1) FMS uses Forms QA-0035 (FMS Supplier/Vendor/Agency Audit Questionnaire) and

QA-0036 (FMS Supplier Vendor (145) Audit Checklist/Questionnaire) to qualify and audit contractors.

(2) FMS is only authorized to contract maintenance work to a non-EASA-certificated

source if FMS is appropriately rated itself to perform the work.

a. FMS is responsible for approving for Return to service each item on which work is performed and for ensuring its airworthiness.

b. Any non-EASA- approved contractor to which work is contracted must be under

the control of FMS’s QAS. Additionally, FMS must inspect each item on which contracted work has been performed for compliance with this supplement.

c. If FMS is unable to determine the quality of contracted work, the work can only be

contracted to an EASA- approved facility that is able to test and/or inspect the work performed and issue a Return to service for the work performed. If the contracted item must be disassembled by FMS to determine the quality of the work performed, then it should not be contracted to a non-EASA-approved source.


(3) Contracting to EASA-approved Facilities

a. If/when FMS contracts functions to another organization that is EASA-approved, the contractor is responsible for approving the Return to service for each item on which it has worked.

b. When considering contracting functions for European Union (EU)-registered

aircraft, the FMS Planner/Purchaser will first coordinate with the FMS Chief Inspector to determine that the EASA-approved Repair Station to which work is contracted, is properly certificated to perform that work. The Chief Inspector will use information provided by FMS Forms QA-0027, QA-0035, and QA-0036 for his/her determination.

(4) Receiving Inspections

a. Refer to Section III of the FMS QCM regarding Receiving, Stores, and Shipping. This section contains procedures including but not limited to:

i. Items received from a non-certificated contract agency, ii. Inspection Personnel assigned to receiving,

iii. Procedures regarding enabling an airworthiness determination of any item

received based on a technical review of the contractor’s source documentation to ensure all portions of the work performed meet the details and specifications of technical data provided for the work and the requirements of the purchase order.

b. As with all repair station documentation, records are retained for two (2) years in

compliance with the recordkeeping requirements of 14 CFR §145.219. (5) Audits

a. Section IX of the RSM provides the procedure for oversight of noncertificated contractors. As noted, depending on the nature and complexity of the service being provided and company specifics, noncertificated contractors may also require scheduled and/or random onsite surveillance inspections during the performance of the maintenance function.

b. The purchase order process provides information and is subsequently used during

the receiving process to check compliance regarding details such as specifications of technical data provided for the subject work (reference Section III (Receiving, Stores, and Shipping) of the FMS QCM). Should changes to specifications, technical data, manuals, or procedures occur while an item is at an FMS contractor, the purchase order will be updated.


c. As with all repair station documentation, records are retained for two (2) years in compliance with the recordkeeping requirements of 14 CFR §145.219.

17. HUMAN FACTORS

A. During the Training Needs Assessment, human factors in aircraft maintenance is an element specifically addressed in FMS’s Overall Repair Station Needs. Additionally, during employee indoctrination training, FMS provides its repair station personnel with Human Factor training (reference Repair Station Training Program Manual (TPM)).

B. Human factors is an element considered during both the Analysis/Investigative Stage and

the Corrective Action Stage regarding Taking Corrective Action on Deficiencies (reference QCM Section IX).

C. The Chief Inspector reviews FMS Corrective Action Reports (CAR) (FMS Form QA-0045) during the Annual Training Program Review to provide additional information on adjustments needed to the FMS training program (reference TPM Section II). Additionally, FMS reviews all Corrective Action Request (CAR) (QA-0045) data and determines the need for any recurrent training session(s) (reference TPM Section II).

18. AIR CARRIER LINE STATIONS

A. Repair stations with line maintenance authorization

(1) EASA uses the term line stations, while the FAA uses the term line maintenance authorization in 14 CFR part 145. These terms are synonymous when applied under the terms of the MAG.

B. EASA Certificate

(1) The EASA certificate covers line stations under the surveillance of the FAA, except

those located in one of the EU member states listed in the MAG Agreement, Appendix 2, Annex 2 and holding an FAA line maintenance authorization.

C. Air Carrier (not applicable to FMS) (1) Should FMS also become a 14 CFR part 121 air carrier in addition to holding a

14 CFR part 145 certificate, FMS will revise this procedure to ensure that at least one of its main maintenance facilities is rated for the aircraft type(s) and the scope of work is relevant to the line station(s).


D. Repair Station (1) A 14 CFR part 145 repair station can only be accepted if the Operations Specifications

Part D107 authorizes the certificate holder to perform line maintenance and lists the specific locations for U.S. operators.

NOTE: The FAA does not list EU Operators on the FAA OpSpecs

E. For Each of the Above

(1) The EASA supplement procedure must clearly demonstrate that the quality system covers the air carrier certificate (if applicable), the 14 CFR part 145 certificate and the line stations and all stated activities.

(2) All line stations exercising the privileges of the EASA Part-145 approval must

specifically be listed in this EASA supplement together with associated operator, aircraft type, location, and contract specifying the scope of work for that particular operator.

(3) A copy of the relevant page of this supplement must also be supplied to EASA as part

of the package for initial, renewal, or change (affecting the list of line stations) to the approval. NOTE: EASA approvals should be the same location as those listed on D107 and

cannot be different, standalone, or exceed those of FAA line maintenance authorizations listed on D107.

NOTE: eVID is primarily used to identify line stations of FAA repair stations within the

United States that provide maintenance for U.S. air carriers. EU operators operating under 14 CFR part 129 shall also be listed on D107. Additionally, they have to be identified in the EASA supplement and subsequently in eVID.

19. WORK AWAY FROM FIXED LOCATION

A. If requested, FMS may perform maintenance away from its fixed location on an EU-registered aircraft or article located inside or outside the territory of the United States on a Recurring Basis. The following conditions apply:

(1) FMS may only perform non-routine maintenance, defined by the MAG as urgent defect

rectification, on an EU registered aircraft or articles intended for installation on EU-registered aircraft.

(2) Work is subject to the limitations of FAA OpSpec D100 (Work to be Performed at a Place Other Than the Repair Station Fixed Location).


(3) Procedures in the RSM, Section VII pertaining to Work Performed at Another Location must be adhered to.

(4) For work within the U.S.

a. If performance of the maintenance is within the U.S., the Chief Inspector or his/her designee will inform the responsible PI. Notification to EASA is not required.

(5) For work outside the U.S.

a. If performance of the maintenance is outside the U.S., the Chief Inspector or

his/her designee must inform the responsible PI and notification to EASA shall be sent to the following e-mail address: [email protected]

NOTE: This section is not applicable to line stations addressed in paragraph 18

of this supplement.

FLORIDA MODIFICATION SPECIALISTS, LLC (FMS) SECTION: APPX I EASA SUPPLEMENT PAGE: 1 REPAIR STATION NUMBER 3FMR327B DATE: 03/24/14 REV: 05

1. APPENDIX I (FAA FORM 8130-3)

A. FAA Form 8130-3 is to be completed by authorized FMS personnel. A completed example is provided below.


B. Approval for Return To Service Information Relevant to the European Union.

(1) Approval for Return To Service After Maintenance, Preventive Maintenance, Rebuilding, and Alteration – Products and Articles.

a. Aviation Authorities (AA) in the European Union may recognize an approval for

return-to-service FAA Form 8130-3 only from part 145 repair stations or air carriers that also obtained a European Aviation Safety Agency (EASA) part 145 approval appropriately rated for the product or article at the time the product or article was approved for return to service.

b. Completing FAA Form 8130-3. A product or article approved for return to service

with a dual release on FAA Form 8130-3 is eligible for installation on a United States or European Union registered aircraft. For a dual release, check both boxes in Block 14a and include the following statement in Block 12: “Certifies that the work specified in Block 11/12 was carried out in accordance with EASA Part 145 and in respect to that work the [product/article] is considered ready for release to service under EASA Part 145 approval no. EASA 145.6282.” FMS’s repair station number 3FMR327B must be entered in Block 14c. A dual release certificate can only be issued by facilities that are both FAA and EASA approved located in the United States or Europe listed in Appendix 2 of the safety agreement.

c. Guidance for the use of FAA Form 8130-3 and EASA Form 1 single release for

special cases is referenced in the MAG under the aviation safety agreement between the United States and the European Union. Refer to MAG section B, appendix 1 for the United States.

d. The FAA Form 8130-3 should include the EASA Part-145 release to service

certifying statement with the EASA Part-145 Approval Certificate number in block 12, and specify any overhaul, repairs, alterations, Airworthiness Directives, replacement parts, PMA parts and quote the reference and issue/revision of the approved data used.

e. The signature of the person returning the component to service shall be in block

14b with the FAA Repair Station Certificate number in block 14c.

f. The status of the component (repaired, inspected, overhauled, etc.) shall appear in block 11 with any relevant comments including detailed references to approved data, Ads, etc., in block 12. Example: “Overhauled in accordance with CMM 111, Section X, Rev 2, S/B 23 and FAA AD xyz complied with. Full details held on WO 456.”


NOTE: In the case of maintenance carried out by a U.S.-based EASA Part-145 approved organization subject to the Agreement, EASA only recognizes the dual release FAA Form 8130-3 for component, engine, or propeller maintenance.

g. Note that the sub clause “except as otherwise specified” is intended for use with

two types of deviations as follows:

i. The case where all required maintenance was not carried out. In this case, list the maintenance not carried out in Block 12 and/or attachments.

ii. The case where the particular maintenance requirement was only EASA-

approved and not FAA-approved. Example: an EASA Airworthiness Directive not approved by the FAA.

C. The following Block-By-Block instructions for completing FAA Form 8130-3 for Approval

for Return To Service were derived from FAA Order 8130.21H. Refer to the current version of FAA Order 8130.21 (as revised) as necessary.

Block 1. Approving Civil Aviation Authority/Country. FAA/United States. (Preprinted.) Block 2. Authorized Release Certificate, FAA Form 8130-3, Airworthiness Approval

Tag. (Preprinted.) Block 3. FAA Form Tracking Number. Enter the unique number established by the

numbering system. Further information may be found in paragraph 3-1i of FAA Order 8130.21H (as revised).

Block 4. Enter Florida Modification Specialists, LLC (3FMR327B), 3430 Flightline

Drive Lakeland, Florida 33811 U.S.A. FMS’s logo or other identification of the organization is permitted if it can be contained within the block.

Block 5. Work Order/Contract/Invoice Number.

Fill in the work order number, contract number, and/or invoice number related to the shipment list, or maintenance release authorization number, and state the number of pages attached to the form, including dates, if applicable. If the shipment list contains the information required in Blocks 6 through 11, the respective blocks may be left blank if a list is attached to the form. In this case, the following statement must be entered in Block 12: “This is the certification statement for the articles listed on the attached document dated _________, containing pages ______ through ______.” In addition, the shipping list must cross-reference the form tracking number located in Block 3. (Refer to appendix A, figure A-4, of FAA Order 8130.21H (as revised)).

If a work order/contract/invoice number is not available, enter “N/A.”


Block 6. Item. When FAA Form 8130-3 is issued, a single item number or multiple item numbers (for example, same item with different serial numbers) may be used for the same part number. Multiple items must be numbered in sequence, although not necessarily beginning with the number one (for example, 0040, 0050, 0062, 0063). If a separate listing is used, enter “List Attached” (refer to paragraph 3-6e of FAA Order 8130.21H (as revised) for further instructions).

Block 7. Description. Enter the name or description of the product or article.

Preference should be given to the term used in the instructions for continued airworthiness or maintenance data (for example, illustrated parts catalog, aircraft maintenance manual, or service bulletin).

Block 8. Part Number. Enter each part number of the product or article. In case of an

aircraft engine or propeller, the model designation may be used. If the article being worked is a subassembly that does not have a part number of its own, enter the next higher assembly number followed by the word “subassembly.”

Block 9. Quantity. Enter the quantity of each product or article shipped. Block 10. Serial Number. If the product or article is required by part 45 to be identified

with a serial number, enter it here. Additionally, any other serial number not required by regulation also may be entered. If no serial number is entered in this block, enter “N/A.” If a specific batch or lot number is used, refer to the instructions for Block 12.

Block 11. Status/Work. The following table describes what to enter in a specific

situation. The term entered in Block 11 should reflect the majority of the work performed by the organization. The use of upper or lower case in this block does not matter.


The following are acceptable Block 11 entries for FMS: Enter— For— “Overhauled” A process that ensures the product or article is

in complete conformity with the applicable service tolerances specified in the type certificate holder’s or equipment manufacturer’s instructions for continued airworthiness, or in the data approved or accepted by the authority. The product or article will be at least disassembled, cleaned, inspected, repaired as necessary, reassembled, and tested in accordance with the approved or accepted data.

“Repaired” Repair of defect(s) using an applicable standard.

“Inspected” or “Tested” Examination or measurement in accordance with an applicable standard (for example, visual inspection, functional testing, or bench testing).

“Modified” Alteration of a product or article to conform to an applicable standard

NOTE: The applicable standard must be described in Block 12.

Block 12. Remarks. The use of upper or lower case in this block does not matter.

(1) Describe the work identified in Block 11 and associated results

necessary for the user or installer to determine the airworthiness of the product or article in relation to the work being certified. This can be done either directly or by reference to supporting documentation. If necessary, a separate sheet may be used and referenced from the main FAA Form 8130-3. Each statement must clearly identify which product or article in Block 6 it relates to.

(2) Below are examples of conditions that could necessitate a statement in

this block. These statements may or may not be appropriate depending on the form’s purpose.

(a) Data required by § 43.9, including the reference and revision status.

If other documents such as work orders, shop travelers, or FAA Form 337, Major Repair and Alteration (Airframe, Powerplant, Propeller, or Appliance), are used by the certificate holder to comply with §§ 43.9 and 43.11, they must be specifically referenced in this block.


(b) Compliance with ADs or service bulletins.

(c) Repairs carried out. (d) Modifications carried out. (e) Replacement articles installed. (f) Life-limited parts status (for example, total time, total cycles, time

since new). (g) If a specific batch or lot number is used to control or trace the

product or article, enter the batch or lot number in this block. (h) Deviations from the customer work order. (i) Release statements to satisfy a CAA maintenance requirement. (j) Information needed to support shipment with shortages or

re-assembly after delivery.

Note: Examples in paragraph 3-6l(2)(i) of FAA Order 8130.21H (as revised) show the possibility of dual release against both part 43 and another CAA’s maintenance requirement or the single release by a part 145-approved maintenance facility against a CAA maintenance requirement. However, care should be taken to check the relevant box(es) in Block 14a to validate the release. A dual release requires the approved data to be approved/accepted by both the FAA and appropriate CAA.

Blocks 13a through 13e

Blocks 13a through 13e are not to be used by the repair station. Shade, darken, or otherwise mark to preclude inadvertent or unauthorized use.

Block 14a Approval for Return To Service. Mark the appropriate box(es) indicating which regulations apply to the completed work. If the box “Other regulations specified in Block 12” is marked, then the regulations of the other CAA(s) must be identified in Block 12. At least the left box must be marked, or both boxes may be marked, as appropriate.


(1) The regulations of the other CAA must be specifically identified in Block 12. The completed work can be accomplished in accordance with the regulations of the FAA, or the regulations of the FAA and another CAA. The data used to complete the work must be clearly stated in Block 12 or attached to the form and the attachment identified in Block 12. If the work has been done in accordance with both the regulations of the FAA and another CAA, both boxes must be checked. (Refer to paragraph 3-2a(3) of FAA Order 8130.21H (as revised) for dual release instructions.) Attachments should include the form tracking number of the corresponding FAA Form 8130-3.

Block 14b. Authorized Signature. This space will be completed with the signature of the

authorized person. Only persons specifically authorized are permitted to sign this block. The approval signature must be applied at the time and place of issuance and manually applied, except as provided in paragraph 3-1j of FAA Order 8130.21H (as revised).

Block 14c. Approval/Certificate No. Enter FMS’s repair station number (3FMR327B). Block 14d. Name (Typed or Printed). Enter the typed or printed name of the authorized

representative whose signature appears in Block 14b. Block 14e. Date (dd/mmm/yyyy). The date to be entered in Block 14e for approval for

return to service will be the date on which the original work was completed (refer to § 43.9). The date must be in the following format: two-digit day, first three letters of the month, and four-digit year, for example, 03 Feb 2008. This does not need to be the same as the printing or shipping date, which may occur later. The use or omission of slashes, hyphens, or spaces in the date does not matter.

FLORIDA MODIFICATION SPECIALISTS, LLC (FMS) SECTION: APPX II EASA SUPPLEMENT PAGE: 1 REPAIR STATION NUMBER 3FMR327B DATE: 07/10/12 EASA.145.6282 REV: 02

1. APPENDIX II (EASA AUDIT CHECKLIST)

A. The following is an example of the EASA Audit Checklist outlining the subject elements requiring auditing.

Audit details are contained in the associated narrative audit report. Table KEY: / = planned, X = performed Prepared: Date, sign Chief Inspector or his/her designee Accepted: Date, sign Accountable Manager or his/her designee



Audit details are contained in the associated narrative audit report. Table KEY: / = planned, X = performed Prepared: Date, sign Chief Inspector or his/her designee Accepted: Date, sign Accountable Manager or his/her designee

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