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An agency of the European Union Page 31 of 31 © European Aviation Safety Agency. All rights reserved. ISO9001 Certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA- Internet/Intranet. European Aviation Safety Agency Work Instruction Foreign Part 147 approvals Technical investigation process Doc # WI.CAO.00013-002 Approval Date 09/11/2011 Foreign Part 147 approvals WI.CAO.00013-002 Name Validation Date Prepared by: Alessandro ZANUZZI Validated 13/10/2011 Verified by: Karl SPECHT Validated 13/10/2011 Reviewed by: Oscar FERREIRA Validated 13/10/2011 Approved by: Wilfried SCHULZE Validated 25/10/2011 Authorised by: Francesco BANAL Validated 09/11/2011
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Page 1: Foreign Part 145 approvals - EASA€¦  · Web viewForeign Part 147 approvals Technical investigation process. Doc # WI.CAO.00013-002. Approval Date. 09/11/2011. An agency of the

European Aviation Safety Agency Work InstructionForeign Part 147 approvals Technical investigation process

Doc # WI.CAO.00013-002Approval Date 09/11/2011

Foreign Part 147 approvals

WI.CAO.00013-002

Name Validation Date

Prepared by: Alessandro ZANUZZI Validated 13/10/2011

Verified by: Karl SPECHT Validated 13/10/2011

Reviewed by: Oscar FERREIRA Validated 13/10/2011

Approved by: Wilfried SCHULZE Validated 25/10/2011

Authorised by: Francesco BANAL Validated 09/11/2011

© European Aviation Safety Agency. All rights reserved. ISO9001 Certified.Proprietary document. Copies are not controlled. Confirm revision status through the EASA-Internet/Intranet.

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DOCUMENT CONTROL SHEET

Reference documents

a) Procedures

PR.CAO.00005 - Foreign Part 147 approval

b) Internal documents

Log of issuesIssue Issue date Change description001 09/11/2011 First issue002 01/09/2014 Migration of Quality documents in compliance with Convergence project

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0. INTRODUCTION

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0.1 Table of contents

0. INTRODUCTION..................................................................................................................................30.1 Table of contents.............................................................................................................................40.2 Definitions and Abbreviations..........................................................................................................50.3 Scope...............................................................................................................................................60.4 Purpose............................................................................................................................................60.5 Communication................................................................................................................................60.6 General principles............................................................................................................................6

1. Technical investigation.........................................................................................................................71.1 Approval of the MTOE in accordance with Part 147.B.110 & Part 147.A.140.................................81.2 Acceptance of Management Personnel in accordance with 147.A.105 (a), (b) and (g)..................9

0.1.1......................................................................................................................................................91.3 Approval of courses (for type training and basic training)..............................................................101.4 Audit of a Part 147 Maintenance Training Organisation................................................................111.5 Part 147 Audit report......................................................................................................................121.6 Auditors’ qualification requirements...............................................................................................12

2. Management of findings.....................................................................................................................132.1 Level 1 findings..............................................................................................................................142.2 Level 2 findings..............................................................................................................................162.3 Tracking and closure of Level 1 and Level 2 findings:...................................................................17

3. Recommendation of an approval........................................................................................................183.1 Contact points when recommending an approval..........................................................................193.2 Recommendation package............................................................................................................203.2.1 Completion...............................................................................................................................203.2.2 Quality check............................................................................................................................21

4. General time frames...........................................................................................................................224.1 Time frame for an Initial Part 147 Approval........................................................................................234.2 Time frame for continuation of Part 147 Approval..............................................................................245. Administrative issues..........................................................................................................................25

5.1 Team size & frequency of audit.....................................................................................................265.2 Working hours................................................................................................................................275.3 Record keeping..............................................................................................................................27

6. Forms.................................................................................................................................................286.1 EASA Form 22 Foreign..................................................................................................................296.2 MTOE/F4 Technical Visa (FO.CAO.00095)...................................................................................296.3 Surveillance Plan (TE.CAO.00096)...............................................................................................296.4 Part 147 Course Approval Forms..................................................................................................29

7. User Guides........................................................................................................................................307.1 UG.CAO.00009“Foreign Part 147 approvals User guide for NAA /QE / EASA”............................317.2 UG.CAO.00014 “Foreign Part 147 approvals - User guide for Maintenance Training Organization Exposition”..............................................................................................................................................317.3 UG.CAO.00015“Foreign Part 147 approvals - User guide for Applicants......................................31

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0.2 Definitions and Abbreviations AAM ADMINISTRATIVE ARRANGEMENT ON MAINTENANCE (TCCA/EASA)AAM-G ADMINISTRATIVE ARRANGEMENT ON MAINTENANCE GUIDANCEA&P APPLICATIONS AND PROCUREMENTS SERVICESAMC ACCEPTABLE MEANS OF COMPLIANCEAMO APPROVED MAINTENANCE ORGANISATIONBASA BILATERAL AVIATION SAFETY AGREEMENT (US/EUROPE)CAA CONTINUING AIRWORTHINESS AUTHORITY CAMO CONTINUING AIRWORTHINESS MANAGEMENT ORGANISATIONCAMOC CONTINUING AIRWORTHINESS MANAGEMENT OVERSIGHT COORDINATORCAN145 CANADIAN PART 145CAOM CONTINUING AIRWORTHINESS ORGANISATIONS MANAGERCAO CONTINUING AIRWORTHINESS ORGANISATIONDA DESIGNATED AUTHORITYEASA EUROPEAN AVIATION SAFETY AGENCYEASATL EASA TEAM LEADEREU EUROPEAN UNIONF145 FOREIGN PART 145F147 FOREIGN PART 147FAA FEDERAL AVIATION ADMINISTRATIONGM EASA GUIDANCE MATERIALMAST MAINTENANCE STANDARDISATION TEAMMAG MAINTENANCE ANNEX GUIDANCEMIST MAINTENANCE INTERNATIONAL STANDARDISATION TEAMMOA MAINTENANCE ORGANISATION APPROVALMOAP MAINTENANCE ORGANISATION APPROVAL PROCEDURESMOC MAINTENANCE OVERSIGHT COORDINATOR MOE MAINTENANCE ORGANISATION EXPOSITIONMOR MANDATORY OCCURRENCE REPORTING MTO MAINTENANCE TRAINING ORGANISATIONMTOA MAINTENANCE TRAINING ORGANISATION APPROVALMTOAP MAINTENANCE TRAINING ORGANISATION APPROVAL PROCEDURESMTOC MAINTENANCE TRAINING OVERSIGHT COORDINATORMTOE MAINTENANCE TRAINING ORGANISATION EXPOSITIONNAA NATIONAL AIRWORTHINESS AUTHORITYNAATL NAA TEAM LEADERPE PANEL OF EXPERTSQE QUALIFIED ENTITYTCCA TRANSPORT CANADA CIVIL AVIATIONUS145 US PART 145WG WORKING GROUPWHOC WORKING HOURS EASA OVERSIGHT COORDINATOR

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0.3 ScopeThe CAO Section is responsible for managing the oversight of Part 147 Organisations based outside the EU Member States (hereafter referenced as “Foreign Part 147 organisations”).

This work instruction is complementary to the requirements of Implementing Rule - Regulation EU 2042/2003 Annex IV, Part-147 and AMC “as amended” does not supersede or replace the information defined within this document.

0.4 Purpose The purpose of this work instruction is to assist the NAA TL and the EASA TL in the management of the “Technical investigation” for:

Initial approval Change of approval Continuation of approval

0.5 Communication All documents and correspondences between the Applicant, the overseeing authority and EASA shall be in the English language unless otherwise agreed by EASA.

0.6 General principles The Oversight of a foreign MTO could be either carried out directly by an EASA Team Leader, by an Accredited NAA or a Qualified Entity. However EASA remains the competent authority responsible for the final approval and associated document as per section B of Part 147.

This work instruction:

Is therefore aimed to detail the procedure to be implemented by either EASATL, or NAA/QE TL when acting on behalf of EASA, on foreign 147 approvals. Where the process differs between EASA TL and NAA/QE TL separate columns will be used.

Defines the various stages of initial, continuation, change, suspension and revocation of EASA approval certificates.

Provides a list of forms and associated user guides to be used when dealing with Foreign Part 147 approvals.

The forms, checklists and user guides addressed within the text and that have to be used by stakeholders are highlighted in green.The two last chapters of this Work Instruction provide:

a list of forms and checklist, a list of user guides

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1. Technical investigation

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1.1 Approval of the MTOE in accordance with Part 147.B.110 & Part 147.A.140

Part 147 Requirement EASA Accredited NAA/QEPart 147.B.110 §a(1)Part 147.A.140Part 147 AMC Appendix IThe competent authority shall formally review Initial issue of the Exposition

The EASATL or NAA/QE TL verifies the compliance of the Exposition with Part 147 requirements.When satisfied, he/she recommends the approval using “MTOE/F4 Technical Visa - Form FO.CAO.00095” and sends it to the EASA MTOC.The review of MTOE should also include the associated procedures and lists when managed separately.

Part 147.A.140 & AMC 147.A.140Direct Approval of MOE amendments

The EASATL or NAA/QE TL verifies the compliance of the Exposition with Part 147 requirements.When satisfied, he/she recommends the approval using “MTOE/F4 Technical Visa - Form FO.CAO.00095” and sends it to the EASA MTOC.The review of MOE should also include the associated procedures and lists when managed separately.

EASAFormal MTOE approval notification

The approval of the Exposition is formally notified in writing to the applicant by using the Letter F7 10 “Approval of MTOE”The approval of MOE should also include the associated procedures and lists when managed separately.

Part 147.A.140 §(c)Indirect Approval of MTOE amendment

The indirect approval consists in the MTO Quality System approving documents in accordance with a procedure included to the MTOE and therefore to be approved by the Authority.

The “indirect approval” privilege shall be based upon the NAA/QE TL or the EASATL confidence on the organisation structure and ability of the quality system to comply and remain compliant with the regulation.

This “indirect approval” cannot be granted at the time of the initial approval and in any case cannot be granted before the first 2 year period has been completed and found satisfactory.

Such a procedure for indirect approval can only apply to minor changes. The overseeing authority must receive a copy of such minor changes when

“indirectly” approved. The NAA/QE TL or EASATL should acknowledge receipt in writing of the

amendment to the Organisation. EASA MTOC shall be copied in.

Part 147.B.110 §a(1)Part 147.A.140Part 147 AMC Appendix IVerification that the MTOE procedures comply with Part 147

The EASATL or the NAATL verifies that the procedures specified in the Exposition comply with Part 147 by using UG.CAO.00014 “Foreign Part 147 approvals - User guide for Maintenance Training Organisation Exposition” as reference material.

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1.2 Acceptance of Management Personnel in accordance with 147.A.105 (a), (b) and (g)

0.1.1Part 147 Requirement EASA Accredited NAA/ QE

147.A.105 §(b) and & (g) AMC 147.A.105 §(b) and & (g)Formal acceptance of the management personnel

The EASATL or NAA/QE TL verifies the compliance of the Form 4’s with Part 147 requirements.When satisfied, he/she recommends the approval using “MTOE/F4 Technical Visa - Form FO.CAO.00095” and sends it to the EASA MTOC.

EASAFormal acceptance of the management personnel

The acceptance of the management personnel is formally notified in writing to the applicant by using the Letter F7 11 “Acceptance of nominated personnel” and by signing the Form 4s’.

147.A.105 §(a)Acceptance of the Accountable Manager

Provided the requirements of Part 147.A.105 (a) are complied with, acceptance of the Accountable Manager is formalized by the approval of the Maintenance Training Organisation Exposition containing the Accountable Manager’s signed commitment.However the MTO may also provide an EASA F4 to demonstrate compliance of the Accountable Manager with the relevant Part 147 requirements.In any case when satisfied, he/she recommends the approval using the “MTOE/F4 Technical Visa - FO.CAO.00095” and sends it to the EASA MTOC.

EASAFormal acceptance of the Accountable Manager

The acceptance of the Accountable Manager is formally notified to the applicant by using the Letter F7 10 “Approval of MTOE”. However when provided the F4 shall be signed and attached to the letter.

147 B 115 & GM 147.B.115Changes of Management Personnel

The EASATL or NAA/QE TL verifies the compliance of the Form 4’s with Part 147 requirements.When satisfied, he/she recommends the approval using “MTOE/F4 Technical Visa - Form FO.CAO.00095” and sends it to the EASA MTOC (1).

147 B 115 & GM 147.B.115Changes of Management Personnel

The acceptance of the management personnel is formally notified in writing to the applicant by using the Letter “F7 11 “Acceptance of nominated personnel” and by signing the Form 4s’.

Note: The EASATL or NAA/QE TL should have adequate control established through the MTOE procedure that they are timely informed by the Organisation of any change of the Management personnel.Note: The EASATL or NAA/QE TL shall hold a meeting with the Accountable Manager at least once during the investigation for initial approval to ensure he/she understands his/her responsibilities under Part 147. The Accountable Manager should be met minimum once during the 2 year surveillance cycle.Note: For any management personnel change the organisation shall supply EASATL or NAA/QE TL with an amendment to the MTOE. The approval of the MTOE shall be done according to paragraph. 1.1 of this work instruction.

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1.3 Approval of courses (for type training and basic training)

EASA Accredited NAA/ QEReview of the Course Material

A cross reference should be made to the submitted Form 12 supporting the application to ensure the correct course material has been submitted. The detailed training programme, Multi Choice Questions and essay questions where applicable, MTOE revision (using the relevant EASA Course Approval Forms listed on the first page of this Working instruction) and course notes as provided by the applicant should be examined in accordance with the relevant Part 147, Part 66 requirements, this working instruction and the G.M.

Approval of the submitted material

Once satisfied the submitted material is compliant with the current regulations and this technical procedure, the submitted course approval form should be signed by the EASA nominated CATL or the NAA/QE Team Leader (NAA/QE TL). A copy of the form will be annexed to the form 22 recommending the course approval. A copy should be made for the company file to be kept by the NAA responsible for that approval. The submitted material may be sent back to the applicant or held on file at the NAA/QE. Where an NAA/QE has the oversight of a large Part 147 approved company offering courses on a number of aircraft it is acceptable not to keep these documents.

Changes to an approved Course

Changes to an approved course shall be notified by the applicant to the nominated CATL or the NAA/QE Team Leader (NAA/QE TL) by using a course approval form. This form shall be reviewed and accepted by the nominated CATL or the NAA/QE Team Leader (NAA/QE TL). A copy shall be kept in the organisations file of the nominated CATL or the NAA/QE Team Leader (NAA/QE TL)

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1.4 Audit of a Part 147 Maintenance Training Organisation.As soon as the draft of the MTOE, the EASA Forms 4, the associated documents, the Quality Assurance Manager statement, the audit report if requested, are deemed acceptable, the accredited NAA/QE TL or EASATL initiates the on site investigation in accordance with Section B of Part 147, its associated Acceptable Means of Compliance (AMC) / Guidance Material (GM) and Internal CAO procedures and work instructions.

EASA Accredited NAA/ QEPreparation The audit plan should be prepared by the Auditor/Team Leader by taking into account the available

resources (audit team) and the scope of work of the Organisation. The plan should include compliance checking against the particular regulation and the current MTOE revision by auditing a cross section of the Organisation’s activities. The audit plan should be notified to the Organisation.For initial approvals and changes of approval, a Statement signed by the Organisation Quality Assurance Manager shall always be provided before the audit takes place confirming that processes, facilities, documentation, training devices and personnel subject to the application have been reviewed and audited showing compliance with all applicable requirements. The relevant audit report shall be requested by the EASATL or NAA/QE TL.

The following points should be considered when preparing the audit plan:o Any follow-up actions from previous audits where necessary;o Dates and places where the audit activities are to be conductedo Audit scope, including identification of the organisational and functional units and processes

to be audited;o Quality Assurance Manager Compliance Statement and when requested the audit reporto Expected time and duration of audit activities, including meetings with the auditee’s

management and audit team meetings.

Achievement An opening meeting will be held with the auditee’s management. The following points should be considered when carrying out the meeting:

o Confirmation of the audit schedule (including the scope of the audit).o Explanation on the method used for reporting nonconformities and dealing with Level 1

finding.All information relevant to the audit objectives, scope and criteria will be collected by appropriate sampling (through interviews, observation of activities, review of documents and records) and verified. It is therefore understood that only verifiable information will be recorded as audit evidence.The audit evidence will be evaluated against the audit objective and references in order to determine findings. The audit team will review the findings at appropriate stages of the audit with the auditees in order to prevent any future misunderstanding. All non conformities and their supporting evidence must be recorded where applicable to allow traceability.Prior to the closing meeting, the audit team shall review the audit findings and evidence collected against the current/intended scope of approval, agree on level* and time scales and prepare the audit conclusions to be presented.A closing meeting, chaired by the audit Team Leader will be held to present the audit findings and conclusions to the auditees in order to ensure that they are understood and accepted. The auditee will be given the opportunity to discuss any non-compliance identified. Corrective actions and an acceptable timeframe for implementation could be also discussed.

* Classification of Level 1 findings is subject to prior confirmation by the EASA MTOC (See the relevant paragraph of this W.I.)NOTE: Any finding discovered during the audit must be debriefed to the Organisation. No finding could be added to the audit report that has not been debriefed to the Organisation.NOTE: During the audit of the organisation the EASATL or the NAA/QE TL will crosscheck the number of staff as detailed within the MTOE and the EASA Form 12. He/she will identify any inconsistency with the number of staff required to meet the manpower requirements of the approval scope and rating as detailed in EASA Part-147.A.105 and as detailed in the approved MTOE. The EASATL or the NAA/QE TL shall notify EASA MTOC of such inconsistencies.

1.5 Part 147 Audit report

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EASA Accredited NAA/ QE

Audit form: The report form to be used by the EASATL/ NAA/QE TL is the EASA Form 22 Part 4 “Findings Part 147 compliance status”.

Or NAA/QE could use their own report form for intermediate audits provided no Level 1 finding has been raised.

Intermediate auditThe recommending authority shall copy in the EASA MTOC with all intermediate audit reports sent to the MTO.

Additional audit report

The EASATL could additionally complete a narrative of the areas audited (in line with normal practice) and will show the areas reviewed, the examples checked and where found in compliance. The form of this additional document is at the auditors’ discretion but can be hand written notes (if legible) or a typed report.

The NAA/QE TL could additionally complete a narrative of the areas audited (in line with normal practice) and will show the areas reviewed, the examples checked and where found in compliance. The form of this additional document is at the NAA/QE s’ discretion provided it is described in their procedures

Notification letter

The audit report is transmitted to the applicant together with the Letter F7 12a or 12b “notification of audit findings”.Even when no finding has been raised, a notification letter should be sent to the organisation.

The process and support used to transmit the audit report to the applicant is at the NAA/QE discretion provided it is described in their procedures.

Notification letterin case of Level 1 finding confirmed by EASA

In case of confirmed level 1 finding, the EASATL or NAA/QE TL shall NOT transmit to the Organisation the audit report, but relevant Form 22 recommendation filled in all its Parts to the EASA MTOC.EASA will notify the finding(s) to the Organisation together with the decision against the approval. As audit report, the EASA Form 22 – Part 4 is attached to this notification.

Time frame for generating the Audit Report

The audit report is normally produced at the time of completion of the audit.The formal notification of the findings must be sent to the Organisation within a maximum of 15 calendar days from the end of the audit except in case of level 1 findings where the audit report is to be sent out by EASA.Only those findings discussed and agreed with the Organisation before departure can be included in the report as non-compliances.

1.6 Auditors’ qualification requirements

EASA Accredited NAA/ QE

Auditor’s Qualification requirements

Each auditor should comply with Section B of the relevant Annexes to the Regulation EC 2042/2003.EASATL shall hold and carry a valid “Authorisation for Inspection Letter” (TE.CAO.00008.001) with him/her when performing an investigation.

Each auditor should comply with Section B of the relevant Annexes to the Regulation EC 2042/2003. The qualification requirements defined by the NAA/QE must be developed in its procedure. The auditor should have been qualified according to this procedure and should carry with him/her the proof of the qualification /authorisation when performing investigations on behalf of EASA

Note: The qualification criteria shall include knowledge and experience of auditing techniques, as well as theoretical knowledge and practical experience in the relevant technical matters covered by the relevant Annex to the Regulation EC 2042/2003 and subsequent amendments.

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2. Management of findings

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2.1 Level 1 findingsEASA Accredited NAA

Level 1 finding:In case a significant non-compliance with any applicable requirement of (EC) Regulation 2042/2003 Annex IV falling within the cases detailed in Part 147.A.160 (a), i.e. Level 1 finding, the EASATL or NAA/QE TL must follow the following steps:1. Information to EASA:He/she immediately inform EASA (MTOC, CAOM or the Head of Department) by any available means of communication (phone, e-mail, fax).

CASE 1: In the case that the audit takes place during normal working hours of the office in Cologne the EASATL or the NAA MTOC should contact EASA using the following contact details:

Mr Frederic Mur (EASA MTOC)Email: [email protected](copy [email protected])Tel : +49 221 89 990 4072Fax : +49 221 89 990 4651

Mr Karl Specht (CAOM)Email: [email protected](copy [email protected])Tel : +49 221 89 990 6047Fax : +49 221 89 990 6547

Mr Wilfried Schulze (Head of Organisations Department)Email: [email protected]

(copy [email protected])Tel : +49 221 89 990 4030Fax : +49 221 89 990 4530

CASE 2: In the case the audit takes place outside normal working hours of the office in Cologne due to time differences and week ends, the EASATL or the NAA/QE TL - through the NAA/QE MTOC where possible- should contact EASA by using the following contacts details:

Telephone : +49.170.782.3417E-mail address: [email protected]

This number is being distributed to the NAAs, Air Accident Investigation Boards, major manufacturers and certain other Organisations to enable them to contact the Agency in an emergency. It is not to be used as a general phone number. The dedicated email address functions 24 hours per day, the telephone line, however, is operational Monday to Friday from 5.00 p.m. to 8.00 a.m. the next day) and 24/24 over the weekend or on public holidays.

2. Information to the organisationAs soon as the EASATL or NAA/QE TL identifies a serious safety concern that she/ he feels is possibly a level 1 finding, the organisation must be briefed accordingly explaining that the EASA confirmation is needed prior to formal notification of the level 1 finding.3. Finding description and EASA confirmationThe EASATL or the NAA/QE TL should use the EASA Form 22 – Part 4 to describe and notify the proposed level one finding to EASA.EASA will use the same document to formally notify the final finding classification back to the EASATL or NAA/QE TL.4. Debrief to the organisationOnce the EASA confirmation is received the EASATL or NAA/QE TL should orally brief the Organisation accordingly.5. Audit reportIn case of confirmed level 1 finding, the EASATL/ NAA/QE TL shall NOT transmit to the Organisation the audit report. EASA will notify the finding(s) to the Organisation together with the decision against the approval.6. F22 RecommendationThe EASATL/ NAA/QE TL shall transmit the relevant Form 22 recommendation filled in all its Parts to the EASA MTOC. The Part 5 shall also include the recommendation regarding the certificate.7. Notification to the organisationThe Agency is the competent authority for foreign Part 147 approvals and as such shall take any action in respect to the approval. In case of confirmed level 1 finding EASA will notify the finding(s) to the Organisation together with the decision against the approval. The EASA Form 22 – Part 4 will be used as audit report and be attached to this notification.

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2.2 Level 2 findingsEASA Accredited NAA/QE

Level 2 finding

Level 2 finding:When any non-compliance with any applicable requirement of (EC) Regulation 2042/2003 Annex IV other than a Level 1 finding, the EASATL or the NAA/QE TL should notify the Organisation in writing according to the relevant Part and the paragraph 2.4 “notification report” of this work instruction.

The corrective action period granted by the EASATL or NAA/QE TL must be appropriate to the nature of the finding but in any case initially must not be more than three months.

Note: For an initial Audit the findings should not be classified as Level 1 or 2 as no action can be taken against the certificate. They should however still be tracked to ensure they are closed before the recommendation is made. A maximum of three months shall be allowed to take corrective action for each finding raised during the initial audit. Failure to close these findings during this three months period could lead the Agency to terminate the application.

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2.3 Tracking and closure of Level 1 and Level 2 findings:The NAATL or the EASATL is responsible for tracking the implementation of the corrective action(s).

EASA Accredited NAA/ QE

Tracking of corrective actions

It is the responsibility of the EASATL or the NAA/QE TL to manage both level 1 & 2 finding due dates and also any additional limits imposed by EASA that are addressed in the notification letter.In case due dates are reached without any acceptable actions from the MTO, the EASATL or the NAA/QE MTOC shall inform the EASA MTOC.

Closure of the audit report which includes level one finding

When the EASATL or the NAA/QE TL is satisfied with the corrective actions that have been proposed by the Organisation in respect of finding(s) raised during the audit, he/she notifies in writing the organisation together with the EASA MTOC that the proposed corrective actions are considered to be acceptable.The final closure of the report is subject to an in situ re-instatement audit to confirm the proper implementation of the corrective actions.

Once the EASATL or the NAA/QE TL is satisfied with the implementation of the corrective action, he/she responsible for recording the reference of the corrective actions and the date of closure in the re-instatement EASA Recommendation Form 22.

Closure of the audit report which does not include level one finding.

When the EASATL is satisfied with the actions that have been taken by the Organisation in respect of the finding raised during the audit, he/she notifies the Organisation (in writing) that the non compliances are considered to be closed by using the Letter F7 13 “Closure of non-compliances”. In the mean time the EASATL is responsible for recording the reference of the corrective actions and the date of closure in the EASA recommendation Form 22 – Part 4.

When the NAA/QE TL is satisfied with the actions taken by the Organisation in respect of the finding raised during the audit, he/she should notify the Organisation that the non compliances are considered to be closed. The document used is at the NAA/QE s discretion provided it is described in their procedures. Additionally the NAA/QE TL is responsible for recording the reference of the corrective actions and the date of closure in the audit report. .

Note: Any extension of delay related to level 2 finding should be justified and sent in writing by the Organisation to the EASATL or NAA/QE TL. The EASATL or NAA/QE TL shall notify his/her decision to the Accountable Manager and record such an extension in the Audit report.Such an extension should not be systematically granted. Before extending the initial period the authority must be satisfied with a corrective action plan provided by the ATO.Note: According to Part 147.B.130, when the Organisation cannot meet the timescales specified for Level 2 finding and did not request any extension, the EASATL or the NAA/QE TL should inform the EASA MTOC who will take together with the CAOM the decision to re-classify the Level 2 finding to Level 1 with the associated decision related to the approval (suspension, limitation).Note: The follow-up system used to track that the Organisation meets the timescale specified for finding corrective action is at the NAA/QE s’ discretion provided it is described in their procedures.

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3. Recommendation of an approval

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3.1 Contact points when recommending an approval

The EASA MTOC is the focal point for NAA/QE s for all topics related to Foreign Part 147 Organizations.

The NAA/QE MTOC is the focal point for EASA. In extenuating circumstances a NAA/QE TL may have to contact directly the EASA. In such case and after his acceptance the NAA/QE MTOC should be copied in all related correspondences.

For any technical query or transmission of technical documents the EASA MTOC can be contacted at the following e-mail address:

[email protected]

The initial application and the application for change are directly sent to EASA by the applicant. EASA is responsible for passing the application package to the allocated NAA/QE (MTOC) or the EASATL in order to proceed with the investigation process.

Once the investigation process has been carried out, the NAA/QE MTOC or the EASATL is responsible for providing the EASA MTOC with the recommendation package.

The NAA/QE MTOC a recommendation package should address it to EASA, Organization Approval Section (S.2.3)

Important notes:

1. all documents shall be sent as a package including Form 22, Technical Visa (where applicable), supporting documents (Form 4s etc…).

2. when documents are sent electronically (PDF), the following e-mail address shall be used:

[email protected]

!

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3.2 Recommendation package3.2.1Completion

The accuracy and completeness of the recommendation package is essential to issue an approval based upon full confidence in the recommendation. It is imperative that all the documents submitted to the Agency are thoroughly checked before submission by authorized staff. Only the EASA Forms as detailed in the CAO section procedures have to be used when providing a recommendation for foreign Part 147 approval.

An EASA Recommendation package shall be completed: For the initial issuance of an approval (recommendation for initial approval). For each change of approval (recommendation for change). Every 24 months (recommendation for continuation of approval). For a suspension/revocation when a Level 1 finding is raised. For reinstatement of approval after suspension/limitation.

a) The recommendation package for an Initial application should contain :o the signed recommendation EASA Form 22o the signed MTOE /F4 Technical Visao EASA Form 4 (s) o a copy of the MTOE chapters: 1.6 ”list approved addresses”, 1.9 “List of Approved Courses,o the Form 11 template certificateo a copy of the Form 12o the surveillance plano the organisation’s QAM statement.o The course approval forms

b) The recommendation package for a change of approval should contain :o the signed recommendation EASA Form 22o a copy of the Form 12 (+ copy of the C of I if name change)o the organisation QAM statemento the signed MTOE /F4 Technical Visao EASA Form 4 (s) (as necessary)o a copy of the MTOE chapters: 1.6 ”list approved addresses”, 1.9 “List of Approved Courses,o the form 11 template certificate (as necessary)o the surveillance plan (as necessary)o the course approval forms

c) The recommendation package for a continuation of approval should contain :o the signed recommendation EASA Form 22o the surveillance plan

d) The recommendation package for a suspension/revocation of approval should contain :o the signed recommendation EASA Form 22o the form 11 template certificate (as necessary)o the surveillance plan (as necessary)

e) The recommendation package for a re-instatement of approval should contain :o the signed recommendation EASA Form 22o the organisation QAM Statemento the signed MTOE /F4 Technical Visa (as necessary)o EASA Form 4 (s) (when necessary)o a copy of the MTOE chapters: 1.6 ”list approved addresses”, 1.9 “List of Approved Courses,o the form 11 template certificate (as necessary)o the surveillance plan (as necessary)o the course approval forms if amended

When using the Template FORM 11 to recommend the scope instead of using part 5 of the Form 22, a cross reference between both documents must be recorded.

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The recommendation package shall be checked for completeness and accuracy (quality check) by an authorized person and then sent to EASA MTOC for review:

EASA Accredited NAA/ QE

Authorised person

When the EASA elects to oversee the Organisation, only the EASA MTOC and his deputy are authorised to perform the quality review within the CAO Section.In the case of their absence, the CAOM performs the quality check.

When the investigation is carried out by an accredited NAA/ QE, only the MTOC or the person identified and authorised according to the National procedure can carry out the quality check.

The quality review includes the checking of the following documents:

The completeness of EASA FORM 22 (all 5 parts) and the consistency of the recommendation The completeness of EASA MTOE /F4 Technical Visa (as necessary) EASA Form 4s MOE chapter 1.7 “manpower resources” and chapter 1.9 “scope of approval” (as necessary). The continued surveillance plan The consistency of the EASA Form 12 with the MTOE (“number of staff” & “scope of approval”), EASA

Form 22 and the technical visa Availability of the organisation QAM Statement (as necessary) The completeness of the Course Approval Forms

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4. General time frames

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2 weeks2 weeks

7 months

note 1 : The payment aknowledgment also requests the applicant to prepare the MTOE and associated Form 4s.note 2 : The applicant is informed by EASA regarding the point and address to which the MTOE and Form 4 must be sent.note 3: MTOE study - based upon a good initial issue - by Team Leader and possible corrections by the applicant.note 4: The on-site audit may be extended for one additional month to group audits in the same geographical area to reduce costs.note 5: Implementation of corrective actions and notification to the Team Leader by the applicant.note 6: The Team Leader to close the findings and issue the Recommendation FORM 22

note 7: Form 22 quality check and certificate issuance: 2 weeks NAA review F22 and forward to EASA - 2 weeks EASA to process F22 and issue F11general note 1:The period for initial investigation can be extended if requested the 7 monthperiode is a general.general note 2:It is the applicant's responsibility to provide satisfactory documentation to EASA/ NAA/QE in order to expedite the process.

1 month 3 months3 months

note 1 note 2 note 7note 6note 3 note 4 note 5

1 month

Payment aknowlegement

Exposition study

On site audit

Implementation of corrective actions

Corrective actions

implemented by applicant

Closure of findings and

issuance of Form 22

Allocation letter Certificate Form 11

4.1 Time frame for an Initial Part 147 Approval

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4.2 Time frame for continuation of Part 147 Approval

15/12/2007

30 days 30 days 30 days

note 1 note 2 note 3 note 4

EASA Form 22

note 1 : EASA to send a reminder letter 60 days BEFORE the due date to the NAA. note 2 : the recommendation EASA Form 22 should not be dated more than 30 days BEFORE the due date.note 3: the recommendation EASA Form 22 should not be dated more than 30 days AFTER the due date.note 4: in case of "force majeure", a documented extension request is to be sent to EASAnote 5: EASA send a warning letter when the continuation due date is reached.

EASA Form 22or NAA Form Or NAA Form

15/12/2008

EASA Form 22 EASA Form 22 EASA Form 22

15/12/2006

Initial Certificate

Intermediate audit

Change

Intermediate audit

Continuation due date

EASA's reminder letter EASA's Warning letter

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5. Administrative issues

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5.1 Team size & frequency of audit

EASA Accredited NAA/ QE

Determination of the team size

Normally, one auditor is to be used unless otherwise agreed by EASA.All cases where more than one auditor is to be used must be justified by the NAA/QE MTOC and agreed by EASA prior to the investigation taking place.The criteria that will be applied by EASA to determine the investigation team (more than one auditor) are as follows:

o Complexity of the organisation approvalo Number of sites to be auditedo Type of audit (initial, changes, follow up audits, findings etc.)o Size of the organisationo Nature of the services to be covered by the MTO and its direct impact to

aviation safetyo Appropriate technical experts (may include language needs)o Any additional reason deemed necessary by EASA and justified by a specific

situationIf an accredited NAA elects to use additional staff or trainees for an audit, EASA must be informed in advance. In all such cases any associated costs shall be borne directly by the NAA/QE and not by the applicant or EASA.Trainee staff from EASA may participate in investigation teams at no direct cost to the applicant.

The agency shall allocate man-hours for the oversight of each project. In all cases, where the numbers of man hours are going to be exceeded, the EASATL or NAA/QE MTOC shall provide justification for additional hours.

Frequency of audits

Normally the frequency shall be one visit per year for a type training approved organisation and two visits a year for basic training approved organisation.

For type training approved organisations, this implies that:o A first intermediate audit should be carried out between 6 months and 12 months

from the date the certificate was granted;o The second intermediate audit should take place between 12 and 24 months from the

date of the certificate was granted;o The EASA or NAA/QE should ensure that a period of minimum 6 months and

maximum 18 months between each audit is maintained - never exceeding 24 months from the date the certificate was granted. However the NAA/QE should try to maintain where possible an interval of 12 months between two intermediate audits.

The frequency of audit may be increased when agreed by the EASA MTOCThe criteria to be reviewed by the EASA MTOC for increasing audit frequency are as follows:

o Follow up of audits / findingso Change to approvalo Incident responseo Request by the Agencyo Large complex Organisationo Number of sites covered by approval

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5.2 Working hoursA number of working hours is allocated by the Agency for the management of applications and approvals on its behalf. The allocation of working hours process is detailed in the paragraph «allocation of technical working hours » of the UG.CAO.00009 “Foreign Part 147 approvals User guide for NAA/ QE / EASA”

5.3 Record keepingAs detailed in Part 147.B.20 (c) the period of retention of records associated with the process of issue, change, continuation, suspension, revocation of an Organisation approval is at least 4 years.

Part 145 Requirement

EASA Accredited NAA/ QE

147.B.20 (b)AMC 147.B.20

The competent authorities shall establish a system of record-keeping that allows adequate traceability of the process to issue, continue, change, suspend or revoke each approval.

A scanned copy of : The application package:

o FORM 12o Certificate of Incorporation, etc.

EASA correspondences:o Letterso template letterso EASA FORM 11

The recommendation package received from the EASATL or NAA/QE TL

o Formso EASA Form 22o MTOE /F4 Technical Visao Form 4s’o EASA Surveillance Plano Additional audit reportso QAM statemento Course approval forms

are archived on the V:\ drive in the relevant Organisation electronic file according to the internal Work Instruction IMS.00048 “CAO records management”.The EASATL is responsible to archive the successive MTOE and associated documents on the V:\ drive in the relevant Organisation electronic file according to the internal Work Instruction.CAO Section administration staff is responsible to keep the approvals’ electronic files up to date.

The process of record keeping is at the NAA/QE discretion provided it complies with Section B of the relevant 2042/2003 Annex IV and it is described in their procedures.

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6. Forms

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6.1 EASA Form 22 Foreign

6.2 MTOE/F4 Technical Visa (FO.CAO.00095)

6.3 Surveillance Plan (TE.CAO.00096)

6.4Part 147 Course Approval Forms

FO.CAO.00098: Course Approval - B2 BASIC

FO.CAO.00099: Course Approval – B1.1 & A.1 BASIC

FO.CAO.00100: Course Approval – B1.2 & A.2 BASIC

FO.CAO.00101: Course Approval – B1.3 & A.3 BASIC

FO.CAO.00102: Course Approval – B1.4 & A.4 BASIC

FO.CAO.00103: Course Approval – C TYPE

FO.CAO.00104: Course Approval – B1.1 & B2 TYPE

FO.CAO.00105: Course Approval – B1.1 TYPE

FO.CAO.00106: Course Approval – B1.2 & B2 TYPE

FO.CAO.00107: Course Approval – B1.2 TYPE

FO.CAO.00108: Course Approval – B1.3 & B2 TYPE

FO.CAO.00109: Course Approval – B1.3 TYPE

FO.CAO.00110: Course Approval – B1.4 TYPE

FO.CAO.00111: Course Approval – B1.4 & B2 TYPE

FO.CAO.00112: Course Approval – B2 TYPE

Note: Additional instructions for use of these forms can be found within the document UG.CAO.00009 “Foreign Part 147 approvals User guide for NAA/QE / EASA”

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7. User Guides

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7.1 UG.CAO.00009“Foreign Part 147 approvals User guide for NAA /QE / EASA”

This user guide gives instruction for:o Instruction for use of the EASA Foreign Form 22o Instruction for use of the MTOE/F4 Technical Visao Instruction for desktop audito Instruction for the acceptance of instructors, knowledge examiners and practical assessorso Instruction for allocation of technical working hours

7.2 UG.CAO.00014 “Foreign Part 147 approvals - User guide for Maintenance Training Organization Exposition”

7.3 UG.CAO.00015“Foreign Part 147 approvals - User guide for Applicants

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RECORDS

Appendix A : Operational Documents

Record Step / Related to

Appendix B : External Documents

Record Step / Related to

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