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- Interpretation on "Maintenance release of aircraft not covered by the Basic Regulation"
- Certificate of Recognition Form 149
- EASA policy on Certificates of Release to Service for aircraft maintenance and associated responsibilities of maintenance organisations and CAMOs
- Easy Access Rules for Continuing Airworthiness (Regulation (EU) No 1321/2014), covering all the Annexes of Regulation (EU) No 1321/2014.
What kind of release document is considered equivalent to an EASA Form 1 under the terms of the US-EU Bilateral safety agreement? (AMC M.A.501(a)(5)(a)/AMC 145.A.42(a)(1)(a))
- Block 11 should provide the status of the component (e.g. ‘overhauled’)
- Block 12 should include (or refer to) detailed information on the work performed, the associated approved data (e.g. ‘Overhauled in accordance with CMM 111, Section X, Rev 2, S/B 23 and FAA AD xyz complied with’) as well as the EASA Part-145 statement and approval number.
- Block 14 should at least show “Other regulation specified in block 12” ticked
When do I need a dual release on FAA Form 8130-3 under EU/US bilateral agreement?
Under the terms of the EU/US bilateral agreement (BASA) (see here), a DUAL release is required for acceptance of USED engine/components from an US based repair station.
NOTE: a single EASA release on Form 8130-3 with only “Other regulation specified in block 12” ticked in block 14a is also acceptable for USED engine/components. This is to cover the case where component maintenance includes the installation of a used (sub)component released on an EASA Form 1 with ‘single release’ only, and therefore where the assembly is not eligible for US-registered aircraft.
CAUTION: DUAL release is not acceptable for ‘rebuilt’ engine/components because EASA recognises the term ‘rebuilt’ only as a manufacturing/production release (not a maintenance release) and only for engine.
Can I import a rebuilt engine and associated components from US?
Under the terms of the EU/US bilateral agreement (BASA) (see here), you can import an engine with a ‘rebuilt’ status in block 11, only when it has been released by the original engine manufacturer on a Form 8130-3 using the blocks 13a. to 13e. (left side).
Please note that Form 8130-3 with ‘rebuilt’ status are not acceptable for components other than engine (regardless whether it has been released on left or right side) therefore the components accompanying the rebuilt engine should either be released REPAIRED/OVERHAULED… (right side) or NEW (left side).
What does it mean ‘a release document issued by an organisation under the terms of a bilateral agreement signed by the European Community’ referred in AMC M.A.501(a)5(a)/AMC 145.A.42(a)1a)?
Can the subcontractor’s staff of a part-145 approved organisation issue an EASA Form 1?
One of the fundamentals of subcontracting activities is that, during such maintenance, the part-145 has been temporarily extended to include the subcontractor. Subcontracting can be done only if the part-145 has approved procedures to do it (145.A.75 (b)) and the MOE is amendment to show this new subcontractor.
A certificate of release to service can be signed by a person from the subcontractor who meets the part-145 approved maintenance organisation certifying staff standard approved in the MOE, which means:
- The subcontractor’s staff (who does not need to hold a part-66 licence) must meet the authorisation criteria of the part-145 approved organisation, including the assessment of competence (knowledge, on-the-job performance and experience), continuation training and ongoing competency assessments.
- The subcontractor’s staff must be authorised by the part-145 to issue an EASA Form 1
The certificate of release to service and the EASA Form 1 will always be issued under the maintenance organisation approval reference.
With respect to blend out repairs, is it required to record the depth and area dimensions of material removed during a blend out repair or is it sufficient to simply record that the damage has been repaired as per the SRM?
Yes, the dimensions of the damage and the removed/remaining material should be recorded. This is a very important information in order to assess whether further damage (adjacent or at the same spot) at a later stage would be allowable or not. In addition, it is a safeguard measure in order to be able to determine, during audits, whether the person correctly determined that the damage was within limits.
Does the part-145 quality system need to be subject to monitoring?
Yes, the quality system is part of the activities of the part-145 organisation and therefore it should be monitored.
Point 145.A.65 (c) requires that the quality system monitors that the activities are being performed in accordance with the approved procedures. The quality system procedures are included within these approved procedures. This implies that quality system must be subject to audits and the part-145 organisation audit programme/plan needs to reflect this.
Besides that the audits of the quality system shall satisfy the requirement of independent audits. This is further explained in AMC 145.A.65(c)(1) point 11: the independence of the audits should be established by always ensuring that audits are carried out by personnel not responsible for the functions, procedures or products being checked. So, the quality manager cannot audit the quality system in terms of independence of the audit.
Therefore, to audit the quality system, it is acceptable to:
- use competent personnel from a different section/department in the same organisation not responsible for the quality function/procedure, or,
- contract the independent audit element of the quality system to another organisation or a qualified competent person, or,
- have the quality system is monitored and certified against an internationally recognised quality standards by a certification organisation.
The way the quality system is going to be audited has to be described in the MOE and approved by the competent authority.
Is Part-M applicable to approved Part-145 organisations?
Yes, Part-M is applicable to Part-145 organisations. Article 3(2) of Regulation (EU) 1321/2014 states that organisations and personnel involved in maintenance of aircraft and components shall comply with Part-M. Nevertheless, not all the requirements of Part-M are applicable to Part-145 organisations.
Part-145 organisations shall take into account the following requirements of Part-M:
- M.A.201 (c) – Responsibilities
- M.A.403 (b) – Aircraft defects
- M.A.501 (a) & (c) & (d) – Installation
- M.A.504 (a) & (b) & (d) & (e) – Control of unserviceable components
In addition, Part-145 refers to the following Appendixes of Part-M:
- Appendix II to Part-M (EASA Form 1)
- Appendix IV to Part-M (Class and rating system)
- Appendix IX to AMC M.A.602 and AMC M.A.702 (EASA Form 2)
- Appendix X to AMC M.B.602(a) and AMC M.B.702(a) (EASA Form 4)
Release to service of NDT tasks by part-145 organisations
Certifying staff required
General Release procedure
Release procedure for an NDT inspection
The release of the works carried out on aircraft has to be performed by certifying staff holding a part-66 licence
Licencing of personnel has to follow part-66 regulation
The release is either on the aircraft technical log or issuing an aircraft release to service statement
A part-145 organisation holding an A approval rating on a particular aircraft type and having in its approved scope of work NDT inspections for this aircraft type.
Please note that the release may include not only the NDT task but also the associated tasks (removal of panels, blankets, wires, re-installation, etc), or the NDT task may be part of a base maintenance check.
The release of the works carried out on engines has to be performed by engine’s certifying staff
The certifying staff is qualified following the procedures established by the organisation, part-66 licence is not required.
The release of works performed under class B is done on an EASA form 1 (there are some exceptions for particular cases)
A part-145 organisation holding a B rating approval on a particular engine type and having in its approved scope of work NDT inspections for this engine type.
The release of the works carried out on aircraft has to be performed by components certifying staff
The certifying staff is qualified following the procedures established by the organisation, no need to have a part-66 licence
The release of works performed under class C is done on an EASA form 1 (there are some exceptions for particular cases)
A part-145 organisation holding a C rating approval on a particular component and having in its approved scope of work NDT inspections for this component.
The release of the works carried out on aircraft has to be performed by “specialised services” certifying staff
The certifying staff is qualified following the procedures established by the organisation in compliance with EN4179, part-66 licence is not required.
The release of works performed under class D rating is done on an EASA Form 1 or on a format defined by the organisation in the MOE in compliance with 145.A.50 and approved by the competent authority.
A part-145 organisation holding an D approval on a particular NDT method. The approved scope of work will be NDT inspections on this method.
Are the changes imposed by the EU Regulation 1149/2011 applicable to the Certifying staff qualified in accordance with Appendix IV to part-145?
- The provisions of the paragraph 6 of the Article 6 of the Commission Regulation (EU) No 1321/2014 which were introduced by the Commission Regulation (EU) No 1149/2011 relating to the 10 years limit for obtaining the basic training/experience and 3 years requirement referred to in part-66 Appendix III para 1(a)(iv) relating to the type rating endorsement in part-66 Licence are not applicable to Certifying staff qualified in accordance with Appendix IV.
- The practical type training is required in accordance with para 1 (e) of the Appendix IV to part-145, because in accordance with changes imposed by the Commission Regulation (EU) No 1149/2011, the type training shall consist of the theoretical training and examination and practical training and assessment, as stated by item 1 of Appendix III to part-66.
- On job training required by 66.45(c) is not applicable to the Certifying staff qualified in accordance with Appendix IV.
What are the training requirements for personnel within a Part-145 organisation, other than those contained in Part-66?
The accountable manager shall demonstrate a basic understanding of Part-145.
145.A.30(a) point 3.
The person or group of persons nominated responsible for ensuring that the organisation complies with Part-145 (including the Quality Manager) shall be able to demonstrate
145.A.30(b) point 3.
The organisation shall establish and control the competence of personnel involved in any maintenance, management and/or quality audits in accordance with a procedure and to a standard agreed by the competent authority.
In addition to the necessary expertise related to the job function, competence must include an understanding of the application of human factors and human performance issues appropriate to that person's function in the organisation.
This should include also:
145.A.30(e) and associated AMC/GM.
Appendix IV to AMC 145.A.30(e) and 145.B.10(3).
The organisation shall ensure that personnel who carry out and/or control a continued airworthiness non-destructive test of aircraft structures and/or components are appropriately qualified for the particular non-destructive test in accordance with the European or equivalent Standard recognised by the Agency.
Personnel who carry out any other specialised task shall be appropriately qualified in accordance with officially recognised Standards.
By derogation to this paragraph those personnel specified in paragraphs (g) and (h)(1) and (h)(2), qualified in category B1 or B3 in accordance with Annex III (Part-66) may carry out and/or control colour contrast dye penetrant tests.
145.A.30(f) and AMC 145.A.30(f).
By derogation to paragraphs (g) and (h), in relation to the obligation to comply with Annex III (Part-66), the organisation may use certifying staff qualified in accordance with the following provisions:
1. For organisation facilities located outside the Community territory certifying staff may be qualified in accordance with the national aviation regulations of the State in which the organisation facility is registered subject to the conditions specified in Appendix IV to this Part.
2. For line maintenance carried out at a line station of an organisation which is located outside the Community territory, the certifying staff may be qualified in accordance with the national aviation regulations of the State in which the line station is based, subject to the conditions specified in Appendix IV to this Part.
3. For a repetitive pre-flight airworthiness directive which specifically states that the flight crew may carry out such airworthiness directive, the organisation may issue a limited certification authorisation to the aircraft commander and/or the flight engineer on the basis of the flight crew licence held. However, the organisation shall ensure that sufficient practical training has been carried out to ensure that such aircraft commander or flight engineer can accomplish the airworthiness directive to the required standard.
4. In the case of aircraft operating away from a supported location the organisation may issue a limited certification authorisation to the commander and/or the flight engineer on the basis of the flight crew licence held subject to being satisfied that sufficient practical training has been carried out to ensure that the commander or flight engineer can accomplish the specified task to the required standard. The provisions of this paragraph shall be detailed in an exposition procedure.
5. In the following unforeseen cases, where an aircraft is grounded at a location other than the main base where no appropriate certifying staff are available, the organisation contracted to provide maintenance support may issue a one-off certification authorisation:
(i) to one of its employees holding equivalent type authorisations on aircraft of similar technology, construction and systems; or
(ii) to any person with not less than five years maintenance experience and holding a valid ICAO aircraft maintenance licence rated for the aircraft type requiring certification provided there is no organisation appropriately approved under this Part at that location and the contracted organisation obtains and holds on file evidence of the experience and the licence of that person.
All such cases as specified in this subparagraph shall be reported to the competent authority within seven days of the issuance of such certification authorisation. The organisation issuing the one-off authorisation shall ensure that any such maintenance that could affect flight safety is re-checked by an appropriately approved organisation.
145.A.30(j) and associated AMC/GM.
Appendix IV to Part-145.
In addition to the appropriate requirements of 145.A.30(g) and (h), the organisation shall ensure that certifying staff and support staff have an adequate understanding of the relevant aircraft and/or components to be maintained together with the associated organisation procedures. In the case of certifying staff, this shall be accomplished before the issue or re-issue of the certification authorisation.
145.A.35(a) and AMC 145.A.35(a).
The organisation shall ensure that all certifying staff and support staff are involved in at least six months of actual relevant aircraft or component maintenance experience in any consecutive two year period.
145.A.35(c) and AMC 145.A.35(c).
The organisation shall ensure that all certifying staff and support staff receive sufficient continuation training in each two year period to ensure that such staff have up-to-date knowledge of relevant technology, organisation procedures and human factor issues.
145.A.35(d) and AMC 145.A.35(d).
The organisation shall establish a programme for continuation training for certifying staff and support staff, including a procedure to ensure compliance with the relevant paragraphs of 145.A.35 as the basis for issuing certification authorisations under this Part to certifying staff, and a procedure to ensure compliance with Part 66.
145.A.35(e) and AMC 145.A.35(e).
Except where any of the unforeseen cases of 145.A.30(j)(5) apply, the organisation shall assess all prospective certifying staff for their competence, qualification and capability to carry out their intended certifying duties in accordance with a procedure as specified in the exposition prior to the issue or re-issue of a certification authorisation under this Part.
145.A.35(f) and AMC 145.A.35(f).
The holder of a category A aircraft maintenance licence may only exercise certification privileges on a specific aircraft type following the satisfactory completion of the relevant category A aircraft task training carried out by an organisation appropriately approved in accordance with Annex II (Part-145) or Annex IV (Part-147). This training shall include practical hands on training and theoretical training as appropriate for each task authorised. Satisfactory completion of training shall be demonstrated by an examination or by workplace assessment carried out by the organisation.
145.A.35(n) and AMC 145.A.35(n).
The holder of a category B2 aircraft maintenance licence may only exercise the certification privileges described in point 66.A.20(a)(3)(ii) of Annex III (Part-66) following the satisfactory completion of (i) the relevant category A aircraft task training and (ii) six months of documented practical experience covering the scope of the authorisation that will be issued. The task training shall include practical hands on training and theoretical training as appropriate for each task authorised. Satisfactory completion of training shall be demonstrated by an examination or by workplace assessment. Task training and examination/assessment shall be carried out by the maintenance organisation issuing the certifying staff authorisation. The practical experience shall be also obtained within such maintenance organisation.
145.A.35(o) and AMC 145.A.35(o).
Pre-flight inspections (when the 145 organisation has an agreement with an operator)
It should be demonstrated that the personnel carrying out pre-flight inspections have received appropriate training for the relevant pre-flight inspection tasks based on the operator’s CAME.
145.A.30(a) point 3.
Nominated persons (including the Quality Manager)
145.A.30(b) point 3.
All personnel involved in any maintenance, management and/or quality audits.
145.A.30(e) and associated AMC/GM.
Appendix IV to AMC 145.A.30(e) and 145.B.10(3). (Fuel Tank Safety)
AMC 20-22. (EWIS)
Personnel who carry out and/or control a continued airworthiness non-destructive test of aircraft structures and/or components.
Personnel who carry out any other specialised task shall be appropriately qualified in accordance with officially recognised Standards.
145.A.30(f) and AMC 145.A.30(f).
Certifying staff and support staff
145.A.30(g) and (h) and associated AMC.
145.A.35(a) and AMC 145.A.35(a).
145.A.35(c) and AMC 145.A.35(c).
145.A.35(d) and AMC 145.A.35(d).
145.A.35(e) and AMC 145.A.35(e).
145.A.35(f) and AMC 145.A.35(f).
145.A.35(n) and AMC 145.A.35(n).
145.A.35(o) and AMC 145.A.35(o).
145.A.30(j) and associated AMC/GM.
Appendix IV to Part-145.
Personnel performing Pre-flight inspections (when the 145 organisation has an agreement with an operator)
Shall the maintenance data be available and controlled at all times, even if there is no maintenance work going, or shall it be available only during the performance of maintenance?
The maintenance data either can be arranged directly by the part-145 maintenance organisation (AMO) or provided by the customer/operator as specified by 145.A.45(a) and 145.A.45(g). In both cases, the AMO should demonstrate that the maintenance data used, regardless of the source, is up-to-date. To discharge this responsibility, a procedure should be established to:
(a) control the amendment status of any documents being used; and
(b) regularly check that all amendments are being received, e.g. by subscribing to a document amendment scheme (sufficient in case of direct access to the maintenance data through the DAH/OEM. The subscription to the maintenance data distribution system of the customer/operator is insufficient, additional independent verifications through the original author shall be done).
When the maintenance data is arranged directly by the AMO it shall be available and controlled continuously.
There are certain situations when the maintenance data can be obtained only through the customer/operator. One of the examples would be the maintenance data for the large aircraft. The maintenance data coming from the TC holder is usually customised because of the model/configuration/modification/order of aircraft, so it is normally not possible for the AMO to have this customised maintenance data directly from TC holder without having an aircraft of that type under the contract.
When the maintenance data is provided by the customer/operator, it shall be held and controlled by the AMO during maintenance on the concerned aircraft/component. Whenever the maintenance data is not available or not current, the maintenance shall not be performed and released, as mentioned by 145.A.50(a) and 145.A.80 of the Regulation 1321/2014 correspondingly.
Additionally, maintenance data has direct influence on many processes of the AMO therefore it should also be available during the initial approval and continuous surveillance audits on the AMO to demonstrate the overall capability of the organisation to perform maintenance.
Can a certification maintenance requirement (CMR) be performed by the Flight Crew before flight?
145.A.30(j)(3) is usually not applicable in case the CMRs included in an AD but it is not a “repetitive pre-flight airworthiness directive”,
145.A.30(j)(4) could be used for CMRs as long as all the applicable conditions are met. In particular:
- The aircraft is away from a supported location.
- Sufficient practical training has been carried out.
- There is a procedure in the Maintenance Organisation Exposition.
- The conditions of AMC 145.A.30(j)(4) are met (of other agreed with the competent authority which are consistent with this AMC). Please refer, in particular, to:
- the point 2(i) where it says “minor maintenance or simple checks”, and
- the point 2((i)e of this AMC, which states “Any check/replacement involving simple techniques consistent with this AMC and as agreed by the competent authority”
As a consequence, the competent authority should assess that the test is simple and that all the other conditions mentioned in 145.A.30(j)(4) and associated AMC/GMs are met.
What does the term ‘occasional’ mean in 145.A.75(c)?
Within the privilege described in 145.A.75(c) a Part-145 maintenance organisation may perform line maintenance activity in other-than-approved locations, provided it is considered as ‘occasional’. There is no formal definition of ‘occasional’ in the regulation, AMC and GM, but the need for line maintenance in such case should be understood as arising from special occasion, not frequent, regular or recurrent. The repetitive use of this privilege at the same location should not be foreseen.
Subject to the approval by the Competent Authority, the maintenance organisation should develop in the MOE (e.g. Chapter 2.24 Reference to Specific Maintenance Procedures) the procedures to be followed in such a case: how to assess whether the maintenance can be performed, availability of tools/equipment/material/components/maintenance data, staff, adequacy of the facilities, environmental conditions, quality system etc. In particular, it should describe the maximum duration of such line maintenance activity at that location.
What is the meaning of the Protected Rights in the Appendix IV to Part-145?
The protected rights mentioned in paragraph 2(a) of the Appendix IV to Part-145 were included in the Regulation 2042/2003 for the persons who were already working in a Part-145 organisation in a location situated outside the EU before the entry into force of Part-66. These protected rights allowed those persons to continue exercising (inside that particular Part-145 organisation) the privileges of the certification authorisation issued by that Part-145 organisation without the need to comply with paragraphs 1(c) to 1(f).
If this person changed the employment to a different Part-145 approved organisation after the entry into force of Part-66 (i.e. 28 November 2003), the previous certification authorisation is not valid and he/she needs to receive a new one from the new Part-145 approved organisation. In this case paragraph 2 of Appendix IV is not applicable anymore.
This implies that any new or extended authorisation granted by AMOs to their C/S after the entry into force of Part-66 must comply with paragraphs 1(c) to 1(f) in particular regarding the type training certificates.
I am a colour-blind. Does this prevent me from getting a Part-66 licence or exercising my licence privileges?
Regulation (EU) 1321/2014 does not require any medical examination before applying for a Part-66 licence.
In the past some medical criteria were proposed in JAR-66, but these were removed in order to avoid conflicts with national rules. JAR 66.A.50 had requirements on:
- use of alcohol at work,
- effects of medicines,
- physical conditions, vision, ability to see colours,
- mental conditions.
Current 145.A.30(e) requests certifying staff to receive a human factor training and GM 1 145.A.30 (e) gives guidance about the elements of the training to be imparted:
4 - Human performance & limitations
4.4 Attention and perception
4.5 Situational awareness
4.7 Claustrophobia and physical access
4.11 Workload management
4.13 Alcohol, medication, drugs
4.14 Physical work
4.15 Repetitive tasks / complacency
Common sense recommends the certifying staff not to exercise the privileges of their certification authorisation if they know or suspect that their physical or mental condition renders them unfit to exercise such privileges (impact to the safe maintenance operations). In addition such recommendation may be covered and rendered mandatory by the national requirements of the Member State where you exercise your privileges. Typical examples are for intoxication (alcohol, drugs, etc.).
It is therefore recommended that you inform the management of your maintenance organisation:
- as you should not deviate from the national law;
- as the organisation shall establish and control the competence of personnel; (145.A.30(e) – necessary expertise related to the job function);
- as the organisation shall have a human performance programme in place (145.A.35(e)); and
- as the ICAO safety management system encourages to identify hazards and risks.
Please find an agreement with your company in order to list the maintenance tasks that you are allowed to carry out without jeopardising the aircraft safety.
Note: The same reasoning as explained above applies for any medical condition.
Does EASA plan to release regulation on the management of persons with specific learning difficulties (e.g. dyslexia, attention deficit disorder, hyperactivity,…) who wish to undertake aircraft maintenance training in a Part-147 approved training organisation with the aim of gaining a Part-66 license?
Anybody able to pass the basic knowledge examinations and fulfil the basic experience requirements can get a Part-66 licence. There are no additional conditions such as a medical certificate or any other proof regarding the mental or physical abilities. In other words, people with specific learning difficulties or physical impairments are not discriminated by Part-66 or Part-147.
Obtaining the licence does not give the certification privileges. Before granting such privileges, the maintenance organisation will have first to check the competence, including the assessment of the skills and abilities and considering the Human Factors principles. The scope of the certification authorisation will be commensurate to these competence/abilities. Please note that in some EU Member States additional occupational safety and health requirements may apply (working on heights, confined spaces, etc.).
EASA does not plan to amend the regulations taking into account the cases of people with special needs during examinations: a single Regulation cannot cover all individual cases. This is why Basic Regulation (EU) No. 216/2008 includes the possibility for the Member States to apply Article 14.4 or 14.6 for exemption, after evaluation of these individual cases. To illustrate, such exemptions in the past have been positively instructed for candidates with confirmed dyslexia (i.e. 25% additional time).
I am the holder of a B1.2 licence (i.e “aeroplane piston”). Can I exercise my privileges for piston-engine non-pressurised aeroplanes1 of 2000 kg MTOM and below (i.e. category B3)?
By default, a category B3 licence is included in a category B1.2 licence because the basic knowledge requirements (66.A.25(a)) and the basic experience requirement (66.A.30) for a B3 licence are covered by the similar requirements of a B1.2 licence.
Provided that the qualification requirements are fulfilled, the B1.2 licence holder can release maintenance tasks performed on piston-engine non-pressurised aeroplanes of 2000 kg MTOM and below.
In particular the B1.2 licence holder would have to meet 66.A.20(b), which means that:
- the applicable requirements of Part-M and/or Part-145 will be complied; and
- in the preceding two-year period he/she has 6 months of maintenance experience in accordance with the privileges granted by the aircraft maintenance licence or; met the provision for the issue of the appropriate privileges; and
- he/she has the adequate competence to certify maintenance on the corresponding aircraft; and
- he/she is able to read, write and communicate to an understandable level in the language(s) in which the technical documentation and procedures necessary to support the issue of the certificate of release to service are written.
AMC 66.A.20(b) and GM 66.A.20(b) gives further explanations on the 6-months maintenance experience in the last 2 years, including demonstration of experience on at least one aircraft type per aircraft structure (metal, composite or wood).1
I have passed the aircraft type rating training (TRT) in an approved EASA Part-147 organisation, although I have not completed the basic knowledge training. Is this TRT valid for life? Would it be possible to endorse it on my Part-66 licence as soon as I get one?
Aircraft type rating training must have been started and be completed within the 3 years preceding the application for a type rating endorsement (Part-66, Appendix III, paragraph 1 refers).
It does not make sense to attend in the first instance a TRT course with the intent of getting this TRT later endorsed on the maintenance licence for two main reasons:
- at the time the TRT is gained, the holder has no licence and it may take more than 3 years before the applicant is compliant with the basic knowledge (66.A.25) as well as the experience requirements (66.A.30). Therefore the applicant runs the risk to get its TRT certificate expired at the time he applies for the licence and the TRT endorsement; and
- From an intellectual point of view, this is not logical to demonstrate maintenance competence on a specific aircraft type without having acquired the basic knowledge, skills and attitude related to the maintenance and the technologies used in aviation in general.
Legally speaking the situation is not forbidden. However be sure that you get your licence within the 3-years’ timeframe from the date you passed the TRT course.
I already hold a Part-66 licence and I would like to include an additional basic (sub)category? Which additional (sub)modules are required to be passed for the addition of that new (sub)category?
According to 66.B.100(b), the competent authority shall verify that all required modules of Appendix I to Part-66 related to that new (sub)category sought are met. Credit can be granted as regards to the basic knowledge of the (sub)category for which the licence has been already issued.
This means that a comparison of the basic knowledge (gap analysis) will have to be done between the different (sub)categories. Such a comparison has not been yet done once and for all in Commission Regulation (EU) No 1321/2014 due to the different potential cases (wide diversity of (sub)categories).
Therefore such a comparison should be done by the Member State that has already issued the Part-66 licence, before the applicant is enrolled in such a “gap” basic knowledge course.
Please contact your competent authority, which may have already performed this comparison. Some competent authorities may have already posted such comparison(s) on their websites; however be sure that the comparison relevant to your case is acceptable to the competent authority who issued your licence.
In addition the applicant will have to comply with the additional experience requirements for the new (sub)category sought, as detailed in Appendix IV to Part-66.
I hold a Category A1 Part-66 licence. What are the requirements to extend my licence to Category B1.1?
Basically, the requirements to extend a cat A licence towards a cat B1.1 are demonstration of :
- the basic knowledge required for the relevant subcategory B1.1; and
- the experience required by Appendix IV to Part-66.
Two years of practical maintenance experience on operating aircraft in the B1.1 category (not in the A category) is needed before applying for the extension in addition to the demonstration of basic knowledge required for the relevant subcategory B1.1.
The experience requirement will be reduced by 50% if the applicant has completed an approved Part-147 course relevant to the category extension according to Appendix IV of Part-66.
What is the intention of the requirement regarding the assessment of the OJT. What is the nature of the assessment for an OJT? What are the differences between practical assessment and OJT assessment? What are the objectives of the OJT assessment?
The practical assessment addresses the practical portion of any type training whereas the OJT assessment addresses the additional practical experience necessary to gain in a true maintenance environment as part of the first type rating in a (sub)category, as illustrated by the table below:
|PRACTICAL ASSESSMENT||OJT ASSESSMENT
For the purpose of 66.A.45(c)
What/who is assessed:
Candidates following practical element of type training.
Completeness of the OJT.
Reference: 66.A.45 (a)(b); Appendix III, 4.2.; AMC Appendix III
Reference: 66.A.45 (c); Appendix III, section 6; AMC to Section 6 of Appendix III
Function of assessor:
To perform the final evaluation of the knowledge, skills and attitude of the trainee following the practical element of the type training
To conduct the final assessment of the completed OJT, whereas the candidate’s competence is indirectly justified.
Reference: Appendix III 4.2.; AMC Appendix III
Reference: Appendix III, 6.; AMC to Section 6 of Appendix III 8.
Always in a maintenance organisation approved under Part-145 or M.A. Subpart F with A rating
Reference: Appendix III 1(b)
Reference: Appendix III 6.; AMC to Section 6 of Appendix III 1.
To evaluate if the candidate has gained the required competence in performing safe maintenance, inspections and routine work according to the aircraft documentation and other relevant instructions and tasks as appropriate for the type of aircraft.
To confirm the completion of the required diversity and quantity of OJT, based on the supervisor(s) reports and feedback. It is sufficient that the completion of individual OJT tasks is confirmed by the direct supervisor(s), without being necessary the direct evaluation of the assessor.
Reference: Appendix III, 3.2.
Reference: AMC to Section 6 of Appendix III 7. & 8.
Type of assessment:
The assessment may be:
Reference: AMC to Part-66 Appendix III 2)
Reference: AMC to Section 6 of Appendix III to Part-66
Qualification of the assessor:
The assessment shall be performed by designated assessors appropriately qualified. It means that the assessors should demonstrate training and experience on the assessment process being undertaken and be authorised to do so by the organisation. Guidance about the qualification is given in AMC to Part-66 Appendix III 3.)
The OJT shall be assessed by designated assessors appropriately qualified. It means that the assessors should demonstrate training and experience on the assessment process being undertaken and be authorised to do so by the organisation. Guidance about the qualification is given in AMC to Part-66 Appendix III 3.)
Reference: Appendix III 4.2.; AMC to Part-66 Appendix III 3.)
Reference: Appendix III 6.; AMC to Part-66 Appendix III 3.)
Procedure included in:
Part-145 Exposition Manual (chapter 3.15) or “one-off” direct approval
Reference: Appendix III 1(b); Part-147
Reference: AMC 145.A.70 (a)
(OJT) What is the meaning of the following statement in Part-66 Appendix III, Section 6: “The final assessment of the completed OJT is mandatory and…”?
The completeness of the whole OJT process shall be assessed. The intent of the requirement is not to suggest that:
- there should be an assessment performed by the assessor on top of every task monitored by the supervisor; and/or
- at the very end of the OJT programme, there should be a comprehensive hands-on assessment of the candidate on a real aircraft as an additional and ultimate evaluation
All report(s) or feedback from the supervisor(s) having monitored every actual job task performance or any other source of information (use of manuals and procedures; observance of safety measures, warnings and recommendations; adequate behaviour in the maintenance environment), the designated assessor should be in a position to:
- ensure that the OJT procedure was fully met (in terms of objective and content); and
- check that the competence of the candidate was positively assessed.
In case of doubt, the assessor may decide to proceed him/herself to an additional evaluation of the candidate or perform a gap analysis when the OJT procedure is not fully met such as an insufficient number of tasks or diversity of tasks or unclear supervisor’s report regarding the candidate’s performance. The supervisor should not sign the actual task if the person did not achieve the required competence in safe task performance.
Note: It is worth being reminded here that OJT addresses:
- the first type rating in a (sub)category of aircraft; and
- subsequently addresses young mechanics (e.g. “newcomers”) or mechanics having no experience in that new (sub)category of aircraft (e.g. extension of the license).
AMC to Section 6. of Appendix III to Part-66 gives more clarification about the assessment process and the function of the assessor:
- “It is sufficient that the completion of individual OJT tasks is confirmed by the direct supervisor(s), without being necessary the direct evaluation of the assessor”, and
- “The function of the assessor, as described in Section 6 of Appendix III to Part-66, is to conduct the final assessment of the completed OJT. This assessment should include confirmation of the completion of the required diversity and quantity of OJT and should be based on the supervisor(s) reports and feedback”.
It is left to the decision of the competent authority how to comply with this requirement: the AMC as suggested by the Agency aims at avoiding additional burden, duplication or over-regulation while proposing a simple final evaluation process.
Since the OJT is intended for the first aircraft type endorsement within a given licence (sub)category, does this mean that it can be performed on different aircraft types typical for that (sub)category?
OJT shall be performed on the aircraft type for which the applicant is seeking type endorsement. The objective of the OJT is to gain the required competence and experience in performing safe maintenance on that particular aircraft type.
However, a certain number of tasks may be performed on other aircraft type(s) (typically from the same manufacturer), only in the cases where such tasks are very similar to the tasks applicable to the aircraft type for which the candidate seeks the type endorsement. The AMC to section 6. of Appendix III to Part-66 states: “Tasks should be selected among those applicable to type of aircraft and licence (sub)category applied for.” Tasks applicable to the aircraft type may be found also on other aircraft types, perhaps not many, but some may fulfil the requirement. A good example would be same engine types installed on different aircraft types (i.e. CFM56 installed on A320 Family and B737). The location of LRUs, oil servicing, IDG, generator, filter change, engine standard practices, etc., those tasks often do not depend on the specific aircraft type (even could be performed off-wing or on spare engine), except the tasks belonging to the airframe - engine interface. The similar can also be applied for the same type of APU installed on different aircraft types or a limited number of other components/systems. Consequently, this may be acceptable, if properly justified to the competent authority within the MOE Chapter 3.15. This flexibility provision is applicable for a limited number of tasks and should not be used to conduct the entire OJT on other aircraft type(s) showing similarities.
What should be the content of the OJT procedure in MOE chapter 3.15?
As agreed during the Standardisation Meeting with the competent authorities, as a minimum, the OJT procedure should describe the following elements:
- Content of the OJT: the list of tasks that should be performed during the OJT or a list of generic tasks and the process how to develop a list of particular tasks out of this list of generic tasks,
- Qualifications of the assessor and supervisors performing the OJT,
- OJT logbook/worksheets format and content,
- OJT compliance report format and content
- Production planning for the implementation of OJT (how to plan the tasks),
- Supervision process and the assessment process, what to do if the assessment is not positive,
- Safe release to service of the aircraft after OJT.
Note: AMC to Section 6. of Appendix III to Part-66 should be used when defining the content of the procedure.
I work in a maintenance organisation approved by the competent authority of a country different from the one who issued my Part-66 licence. An OJT programme via MOE chapter 3.15 has been approved by the competent authority of my maintenance organisation. However, my licensing authority refuses to accept the OJT from the organisation I’m working for. Why? What shall I do?
Please review the extracted requirements here below from Part-66 Appendix III, Section 6:
- ‘On-the-Job Training (OJT) shall be approved by the competent authority who has issued the licence.’
- ‘It shall be conducted at and under the control of a maintenance organisation appropriately approved for the maintenance of the particular aircraft type’.
- ‘OJT shall cover a cross section of tasks acceptable to the competent authority’.
- ‘In order to facilitate the verification by the competent authority, demonstration of the OJT shall consist of:
- detailed worksheets/logbook and
- (ii) a compliance report demonstrating how the OJT meets the requirement of this Part.’
Since the procedure in MOE is approved by the competent authority of the maintenance organisation, it can only be used when the licensing authority is the same as the competent authority of the maintenance organisation. AMC 66.B.115(c) states that “in the case where the licensing competent authority is different from the competent authority of the maintenance organisation which provides the OJT, your licensing authority may take into consideration the fact that the maintenance organisation has the OJT programme already accepted by their own competent authority (through chapter 3.15 of the MOE, as described in AMC 145.A.70(a))”.
Since your competent authority is responsible for the issue and extension of your licence, please follow the instruction of your competent authority and try to find a solution based on the above AMC.
How to get an EASA Part-66 Licence?
- In order to get an EASA Part-66 AML (Aircraft Maintenance License), an applicant needs:
- Basic knowledge (66.A.25);
- Basic experience (66.A.30).
- In order to get TR endorsed in the AML, an applicant needs:
- Type Training (Theoretical and Practical) (66.A.45)
- OJT for the first TR (66.A.45).
The following two schemes depict the most common paths and are for information only.
- The first scheme applies to Group 1 aircraft (B1 and B2 licence categories).
- The second scheme applies to other than Group 1 aircraft (B1 and B2 licence categories).
NOTE: Aircraft groups are described in 66.A.5.
These schemes do not override Part-66 requirements nor capture all the possibilities (various licences, educations and experiences). The start and end of each phase can vary depending on individual cases.
For further and detailed information:
- Refer to Part-66 and related AMC/GM; and
- Consult the Competent Authority where you intend to apply for the AML.
An aircraft maintenance licence issued by a country other than EASA Member States cannot be rendered valid as EASA Part-66 AML.
Part-66 licences issued by the countries other than EASA Member States are not mutually recognised in European system.
Click on the pictures to zoom in.
I want to work in an organisation located within the EU. Do I need a Part-66 licence?
Part-66 licences are required for:
- certifying the release to service of aircraft after maintenance,
- work in maintenance organisations as support staff.
Aircraft affected are those covered by the Basic Regulation. See the definition in Articles 1 and 4 of the Basic Regulation.
Release to service of piston-engine non-pressurised aircraft of 2000 Kg MTOM and below not involved in CAT do not need a Part-66 licence until 28 September 2014.
Release to service of ELA1 aeroplanes not involved in CAT do not need a Part-66 licence until 28 September 2015.
Release to service of sailplanes, balloons, and airships do not need a Part-66.
Other activities within maintenance organisations do not need Part-66 licences.
Which are the Part-66 licences?
In a Part-145 approved organisation, the different categories of Part-66 licences are:
Certifying the release of aircraft after:
|A||Minor scheduled line maintenance and simple defect rectification||Line station|
|B1||Maintenance performed on aircraft structure, powerplant and mechanical and electrical systems, avionic systems requiring simple tests to prove their serviceability and no troubleshooting||Line station|
|B3||Maintenance activities on non-pressurized aeroplanes of 2T MTOM and below.||Line station|
|B2||Maintenance performed on avionic and electrical systems and electric and avionics tasks within powerplant and mechanical systems requiring only simple test and minor scheduled line maintenance and simple defect rectification||Line station|
|C||Base maintenance activities||Base|
|Support staff for:|
For personnel studying a qualification at a University or a degree in a country outside of the EU: I am studying aeronautics and I wish to obtain an EASA Part-66 licence? May I get a credit or may I get a licence based on my degree?
No, unless the basic knowledge got outside of the EU is acquired in a Part-147 training organisation approved by EASA, according to 66.B.405.
I hold a Part-66 or a national licence issued by my country, may I get a Part-66 licence valid in EU by conversion?
- there is a bilateral agreement between your country and the EU (the Agency is not aware of any such agreement),
- the national licence was valid within EU before the entry into force of the Regulation.
I hold a JAR-66 licence, may I get a Part-66 licence by conversion in accordance with the conversion process in 66.A.70?
The holder of a JAR-66 licence may get a Part-66 licence by conversion only when the licence has been issued by a JAA Member State which has successfully completed the JAR-66 Review Board process. If a country is not in the list shown in this EASA document, no conversion can be made.
More details are shown on the Mutual recognition page
The holders of a JAR-66 licence issued from a country not in this list are not eligible to a conversion. They are required to demonstrate compliance with all requirements.
I have completed my EASA Part-66 modules for B1 and I have passed all the exams, but I still lack experience to get my licence. Is there a time limit to get the licence ? Will the certificate expire in a few years if I do not get the experience?
According to Commission Regulation (EU) No 1149/2011 of 21 October 2011 (amending Regulation (EC) No 2042/2003), the basic examinations shall be passed and experience shall be acquired within the ten years preceding the application for an aircraft basic licence.
The new regulation also states that for the purpose of time limits related to basic knowledge examinations, basic experience acquired before the Regulation applies, the origin of time shall be the date by which this Regulation applies, which is 01/08/2012 (which means until 31/07/2022).
Can I get a Part-66 licence with Annex II aircraft endorsed on my licence?
Type ratings should be endorsed on the Part-66 licence in accordance with the list of type ratings shown in the ED Decision posted under the Aircraft type ratings for Part-66 aircraft maintenance licence page.
This list does not contain any Annex II aircraft as these are out of the scope of Basic Regulation according to subparagraph 4 of Article 4 on the maintenance field.
However, a Part-66 licence includes a page whose title is: ‘Annex to EASA Form 26’ and this page is dedicated to national privileges. When an aircraft is under the remit of the Member State, then such aircraft may be endorsed under these provisions. This is typically the case of Annex II aircraft.
Is there a requirement to have 6 months’ experience every 2 years to maintain the validity of the Part-66 licence? If I don’t meet anymore the 6 months’ requirement, how can I get back my right to exercise my privileges. If so, on which aircraft may I demonstrate this experience ?
The requirement of 6 months’ experience within the preceding 2 years is only for the validity of the certification authorisation. The licence itself is valid 5 years from the last renewal. Only the certification privileges are affected by the recency of experience.
To regain your experience, you may:
- either continue to accumulate maintenance experience until you gain the missing time required, or
- meet the provisions for the issue of appropriate privileges, which means:
- going to a type-training course again, including OJT as necessary, or
- when the aircraft does not require a training (aircraft belonging in Group 2 or 3), pass a type-examination, including practical assessment. See GM 66.A.20(b)2.
Neither a short period of job training session nor an aircraft type refresher training are acceptable.
Demonstration of experience should be made on similar aircraft.
Definition of ‘similar’ aircraft is provided by the AMC to 66.A.20(b)2.
If I cannot demonstrate 6 months of maintenance experience, do I lose my licence?
No, you lose only your rights to exercise your privileges of certifying staff or support staff. The licence remains valid.
As a category A certifying staff at line, can my authority allow me to carry out more tasks than those specified in AMC 145.A.30(g)?
The list of typical tasks to be carried out by a category A certifying staff at line shown in the AMC include a line r. stating: “Any other task agreed by the competent authority as a simple task for a particular aircraft type. This may include defect deferment when all the following conditions are met:
- there is no need for troubleshooting; and
- the task is in the MEL, and
- the maintenance action required by the MEL is agreed by the competent authority to be simple.
When these conditions are met, your authority may allow other tasks to be carried out under AMC 145.A.30g.
I have attended a type training, may I immediately ask my authority to endorse it on my licence?
Yes, if the following conditions are met for the theoretical + practical parts of type training:
- the course has been attended and the exams passed in a Part-147 approved training organisation,
- or in another organisation, provided the course has been directly approved by the authority who issued the licence as per 66.B.130,
- and for B1 and B2 licences, in case where the aircraft type is the first in a licence category or subcategory, an OJT training has been performed.
I hold a licence with a type rating on Airbus A320 Series, and I wish to add the rating on A330 Series. Do I need a complete course?
As per Appendix I to AMC to Part-66, the A330 type rating is a different rating from the A320, therefore the differences should be covered, and:
- a complete theoretical + practical course is required on A330, or
- a differences training course is also an acceptable solution. See Appendix III point 1(c).
I just got an empty Part-66 licence. I plan now to get type ratings. Are 2 weeks practical training sufficient?
As per the new Regulation (EC) No. 1149/2011, the practical element of training is no longer a question of time. The duration of the practical training should be adequate in order to complete the contents required by paragraph 3.2 of Appendix III to Part-66.
For aeroplanes with a MTOM equal or above 30.000 kg the duration for the practical element of a type rating training course should not be less than two weeks.
In addition, for B1 and B2 licences, where the aircraft is the first in a licence category or subcategory, an OJT training shall be performed.
The Appendix III of Part-66 states that a type training course shall be started and finished within 3 years before the application for a type rating, is this still valid if I started the course before 1 August 2012?
Type training courses started and finished before 01 Aug 2012 can be used for rating endorsement application until 31 July 2015.
Any theoretical type training course finished after 01 Aug 2012 can be used for rating endorsement application until 3 years after they were started (even in the case where they were started before 01 Aug 2012).
Any practical type training course finished after 01 Aug 2012 can be used for rating endorsement application until 3 years after they were started (even in the case where they were started before 01 Aug 2012).
Does OJT (on job training) mean ‘practical training’?
OJT is not a substitution for a practical element of the type training course and it is not any more part of a type rating training, as it was in Part-66 before being changed by Regulation 1149/2011.
66.A.45(c) states the following:
‘ In addition to the requirement of point (b), the endorsement of the first aircraft type rating within a given category/sub-category requires satisfactory completion of the corresponding On the Job Training, as described in Appendix III to Annex III (Part-66) (point 6).’
An OJT is required for the endorsement of the first type rating in a new category/sub-category. It shall be set and carried out in an approved maintenance organisation (Part-145 or M/F). Previous approval by the AML authority is required.
It shall be started and completed within 3 years preceding the application of the type rating endorsement.
Tasks listed in Appendix II of Part-66 for an OJT are not suited to large aircraft. Shall we select the OJT tasks only from this list?
Not only, because it is required that:
- the tasks for an OJT must be representative of the aircraft: this means that the tasks listed in Appendix II which are representative of the aircraft or another model in the type rating should be kept and those not representative be disregarded,
- some tasks should be selected from each paragraph of the Appendix II list: this means that it is not necessary to perform exactly 50% in each ATA chapter,
- new tasks more representative of the type of aircraft may be added by the maintenance organisation,
- the OJT tasks should be selected because of their frequency, safety, novelty: tasks selected among those frequently carried out by the organisation on this type or more related to safety should be deleted.
How tasks for OJT shall be selected for different licences?
The AMC states that the tasks are representative of the licence (sub)category applied for. This means that:
- the tasks should identify whether they relate to a B1.1, B1.3 licence … or to a B2,
- and be adapted to the privilege of each licence category / subcategory as defined in 66.A.20(a)3:
- for a B1 licence: aircraft structure, powerplant and mechanical and electrical systems + work on avionics system with simple test but not including troubleshooting,
- and those related to a B2: avionics, aircraft electrical system tasks and avionics/electrical tasks within mechanical and powerplant systems.
Who is allowed to issue EASA Part-66 licences? Can I apply for a Part-66 licence to EASA?
EASA is not a licensing authority and therefore does not issue any licences. Part-66 licences are issued by the competent authorities of the EU Member States, plus Switzerland, Norway, Iceland and Liechtenstein. The list of the National Aviation Authorities and their contact details can be accessed here: http://easa.europa.eu/the-agency/member-states .
How can I apply for an EASA Part-66 licence? What is required at the time of the application?
An application for an aircraft maintenance licence or change to such licence shall be made on an EASA Form 19 in a manner established by the competent authority and submitted thereto (see Appendix V to Part-66). An application for the change to an EASA Part-66 licence shall be made to the competent authority of the Member State that previously issued the aircraft maintenance licence. Each application shall be supported by documentation to demonstrate compliance with the applicable theoretical knowledge, practical training and experience requirements at the time of application.
Which documentation is required to support the application demonstrating compliance with the experience requirements?
Maintenance experience should be written up in a manner that the reader has a reasonable understanding of where, when and what maintenance constitutes the experience. A task-by-task account is not necessary, but at the same time a bland statement such as “X years maintenance experience completed” would not be acceptable. A maintenance log book detailing the experience is desirable and some competent authorities may require such a log book (see AMC 66.A.10).
Consequently, the format used to evidence the maintenance experience is not strictly defined in the rules and is left at the discretion of the competent authority issuing the licence. Hence, EASA advises you follow the instructions of the competent authority where you intend to apply for.
Where do I gain the required basic maintenance experience? Is it mandatory to gain the required maintenance experience in an EASA approved Part-145 organisation?
According to the AMC 66.A.30(a)(4), aircraft maintenance experience gained within different types of maintenance organisations (under Part-145, M.A. Subpart F, FAR-145, etc.) or under the supervision of independent certifying staff may be accepted by the competent authorities. This means that the aircraft maintenance experience may be accepted by the competent authority when such maintenance is performed in a maintenance organisation which does not necessarily hold an EASA Part-145 approval. However, it is on the competent authority to evaluate whether this experience is acceptable.
Consequently, please contact the competent authority where you intend to apply for a licence, in order to check whether the basic experience would be acceptable, with detailed information on the type of aircraft, its operation and the nature of the work.
I work as a mechanic in the military field on aircraft being also certified for civil operations. In order to obtain the Part-66 licence, why do I need additional experience of civil aircraft maintenance as required by 66.A.30(e) on top of my experience in the military field?
As stated in 66.A.30(e), for mechanics having a military background and seeking a Part-66 licence, the objective is to ensure adequate understanding of the civil aircraft maintenance environment, not only because of possible different aircraft technologies, but also because of practices linked to the civil environment.
Not only the technology or systems of the civil aircraft might differ from the military aircraft version configuration (e.g. no video entertainment system; no sliding chutes; different fuel or electrical systems) but the experience gained in the military environment might also significantly differ from the scope of work of the civil maintenance organisation, its procedures and policies (e.g. use and meaning of the certificate of release to service - EASA Form 1, standard parts, store and tools procedures, use of the maintenance documentation such as ADs, SB, SIL…, quality and safety management system; human factor aspects, continuing airworthiness record systems…).
In addition the interaction with the customers (i.e. the airliners) induces new practices such as use of the aircraft technical log book, MEL, aircraft defect rectification and deferment of items; use of customer documentation (e.g. MPD, MRB, SRM, IPC); interaction with the crew; how to behave with the passengers; special procedure such as (re)fuelling, de-icing /anti-icing; communication with the tower or moving on the apron.
Finally, the requirements for the continuing airworthiness of the aircraft might significantly evolve in the civil environment. To name a few, the following items can be reminded: ADs, SBs, operational directives, EASA requirements; records and archives; repairs and modifications (use of data, EASA/FAA rules; dual-release); special inspections (e.g. CPCP, EWIS); approved maintenance programme and its effectiveness / reliability; occurrence reporting; understanding of MSG-3 methods …
The military regulations widely differ from country to country, with certain countries having military rules similar to the EU ones, while others have very different rules. The 12-month additional civil maintenance experience average (as per AMC 66.A.30(e)), has been agreed by the Member States and accepted as a standard way to demonstrate compliance with the rule to achieve mutual recognition and adequate degree of standardisation.
Is it mandatory to go to a Part-147 approved training organisation to get type training? Can we do this training in a Part-145 approved organisation or at the aircraft manufacturer?
Only approved Part-147 organisations are entitled to conduct type training courses in accordance with Article 6 of the Commission Regulation (EU) No 1321/2014. However, according to Appendix III to Part-66, other than Part-147 organisation (including Part-145 maintenance organisations and manufacturers) can be approved by their competent authorities to provide theoretical element (theoretical training and examination) and/or practical element (practical training and assessment) of aircraft type training. This so called “direct” approval may be given by the competent authority in accordance with 66.B.130 provided:
- This is a one-time approval on a case-by-case basis for a single course or a predefined group of courses i.e. Part-145 approved maintenance organisation cannot receive a permanent approval for aircraft type training.
- The course and the assessment complies with the same standard valid for approved Part-147 organisations; this standard is described in paragraph 1 to 4 of Appendix III to Part-66.
- No Part-147 Certificate of Recognition can be issued for the purpose of the mutual recognition between Member States. However, an appropriate training certificates can be issued after successful completion of both elements.
Directly approved aircraft type training course is only valid for Part-66 AML type rating endorsement in that Member State which has issued this direct approval, which means it cannot be used for aircraft type endorsement in other Member States (no mutual recognition of the certificate), unless this other competent authority has approved the course.
What is a difference between examination and assessment? Why are there two different examination standards, respectively in Part-66 Appendix III, points 4 and 5?
Examination is a written form of demonstration of a certain level of theoretical knowledge by the student based on achievement of the learning objectives, usually performed on completion of a theoretical training course or a portion of a course. The student shall demonstrate, to the levels identified in the table in Appendix III, the detailed theoretical knowledge of the aircraft’s applicable systems, structure, operations, maintenance, repair, and troubleshooting according to approved maintenance data, as well as the use of manuals and approved procedures, including the knowledge of relevant inspections and limitations. The standard, format, pass mark, etc. are defined in Appendix III, 4.1. The examination shall be performed by the appropriately trained and approved examiner.
Assessment is a practical form of measuring the competence of the student by evaluating three major factors associated to the learning objectives: knowledge, skills and attitude, usually performed on completion of a practical training course. The assessment should focus on the competencies relevant to the aircraft type and its maintenance. The principles on how to perform the competence assessments are given in the AMCs to Part-66, Appendix III. The assessment shall be performed by appropriately trained and approved assessors.
Regarding Part-66 Appendix III, point 5., “Type Examination Standard” does not apply to the examination performed as part of type training. This point only applies to those cases where type examination is performed as a substitute for type training, which means it is intended for the examinations conducted by (or on behalf of) the competent authority on those aircraft that do not require a type training (typically Group 2 and Group 3 aircraft according to Appendix I to the AMCs to Part-66). So, it is true that the examiners authorised by the competent authority shall not have been involved in the applicant's training. In all other cases AMC to Part-66 Appendix III applies, which means that the roles of the assessor and the instructor may be combined for the practical elements, depending on the size of the organisation.
Regarding the roles of examiners and assessors, these are different functions (which does not prevent that one person can’t be authorised both as examiner and assessor). Normally, these functions should not be confused. The expression “The examination shall be oral, written or practical assessment based, or a combination thereof, …” applies only for Section 5, i.e. “Type Examination Standard”.
Regarding the bullet #6 of 66.B.125(b)1. “aeroplane multiple piston engines — metal structure, either full group or manufacturer group”, what are the correct license conversion provisions for those airplanes moved to Group 1 by Regulation 1149/2011?
These provisions were unintentionally missing when 66.B.125 was initially adopted with Regulation 1149/2011.
The Agency has addressed this issue and proposed to amend the point (Opinion 2005-15), as follows:
- “aeroplane multiple piston engines — metal structure, either full group or manufacturer group: converted to ‘full group 3’ plus the aircraft type ratings for those aeroplanes with multiple piston engines of the corresponding full/manufacturer group which are in Group 1. For the B1 licence, the following limitations shall be included: composite-structure aeroplanes, wooden-structure aeroplanes and metal-tubing and fabric aeroplanes.”
As regard to the approval of the continuing airworthiness organisations, what is the sharing of responsibilities between EASA and the EASA Member States? How to get a list of the EASA approved continuing airworthiness organisations?
According to Article 20 of (EC) No.216/2008 on common rules in the field of civil aviation and establishing a EASA, the Agency is responsible for :
- The management of all applications for organisations whose principal place of business is outside the territory of the EASA Member States (MS) for EASA Part-145 maintenance organisation approvals (MOA), EASA Part-147 maintenance training organisation approvals (MTOA), EASA Part-M Subpart G continuing airworthiness management organisation (CAMO) and EASA Part-M Subpart F approvals (Subpart F).
- The oversight of related certificates and their continued surveillance.
These activities are as follows:
- MOA: Part-145 organisations ('Foreign', USA and Canada ),
- MTOA: Part-147 organisations,
- CAMO: Part-M Subpart G organisations,
- Subpart F : Part-M Subpart F organisations.
Such organisations, generally nicknamed as “foreign” organisations, are managed by EASA in accordance with the relevant Annexes of Regulation (EU) No.1321/2014 and the associated EASA procedures. For more information, see Continuing-airworthiness-organisations where the lists of such “foreign” organisations are available as well as the fees and charges Regulations.
The management of all applications for organisations whose principal place of business is inside the territory of the EASA Member States (MS) is performed by the competent authorities of these MS.
Therefore, information about continuing airworthiness management organisations, maintenance organisations and maintenance training organisation which have principal place of business within any of the EASA MS is kept up-to-date by the competent authorities from these EASA MS. You may contact these authorities at http://easa.europa.eu/the-agency/member-states or consult their public websites when the MS accepted to publish these lists on a voluntary basis.
What is the difference between Commission Regulation (EU) No 1321/2014 of 26 November 2014 and Commission Regulation (EC) No 2042/2003 as amended?
Commission Regulation (EU) No 1321/2014 of 26 November 2014 is an official consolidated version of Commission Regulation (EC) No 2042/2003 and its amendments published up to date, as follows:
- (EC) No 707/2006;
- (EC) No 376/2007;
- (EC) No 1056/2008;
- (EU) No 127/2010;
- (EU) No 962/2010;
- (EU) No 1149/2011; and
- (EU) No 593/2012.
You can access the various lingual and format versions at: http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1421934905395&uri=CELEX:32014R1321 .
Commission Regulation (EU) No 1321/2014 (recast) repeals Regulation (EC) 2042/2003 and its amendments. Its date of application is 20 days after 17/12/2014 (date of publication in the Official Journal).
Some subsequent changes in that new Regulation compared to the old one(s) were deemed necessary but remain very minor, without any impact in its implementation. The following items can be mentioned:
- The Cover Regulation, i.e. the recitals and articles at the beginning of the document have been adjusted;
- Article 6(3) of Regulation (EU) 1321/2014 introduces new provisions related to the minimum syllabus of certifying staff type rating training in the operational suitability data for the relevant type in accordance with Regulation (EU) No 748/2012, which further refers to Part-66 Appendix III points 1 (a)(ii) and (b)(ii).
- Some editorial corrections were introduced with no effect in its implementation.
- Regulation (EU) No 1321/2014 contains references to Regulation (EC) 2042/2003 in the approval certificates (EASA Forms). These references will be changed with the next amending regulation planned before summer 2015.Until that moment the templates for the certificates and forms shall be used as published in Regulation (EU) 1321/2014
The existing approved AMCs/GMs covered by the EASA Decisions, which complemented (EC) 2042/2003 as amended , keep on being valid for newly published Commission Regulation (EU) 1321/2014.
Is it possible to grant a Part-147 approval to a training organisation which intend to conduct only training on one or only several modules?
No, a Part-147 approval can only be granted to an organisation which plans to conduct training on all the modules related to a (sub)category of an aircraft maintenance licence, so that a full understanding of the training needs, interfaces and examination relative to that (sub)category of licence is achieved.
However, some modules may be sub-contracted as mentioned in 147.A.145(d).
It does not mean that the Part-147 organisation is not allowed to conduct courses on just one module. In particular, in the case of limitations resulting from the conversion process, limitations can be lifted through the teaching and/or examination of one module or a part of a module.
Can an examination be limited to some modules only, or one module only or part of a module only?
As mentioned in the previous question, for some particular cases, the basic training need to be conducted and the relevant examination to be passed on some modules only or one module or part of a module (this is typically the case where the holder of a licence applies for removing some limitations mentioned in his/her licence).
However, the Part-147 organisation should be capable of conducting the full course relative to the (sub)category sought, so that they can run the examination.
Is it possible to grant a Part-147 approval to a training organisation which intend to conduct only basic knowledge examinations?
No, a Part-147 approval can only be granted to an organisation which can prove its capability to conduct training and examinations on a complete syllabus of at least one (sub)category of the Part-66 licence. Only in the case the organisation holds the approval for the complete basic training course, it may conduct basic examinations not being an integral part of the approved basic training course.
Part-147 approved organisations have the privilege to carry out basic examinations on behalf of the competent authority. Does this imply that the said authority has to supply or approve examination questions?
No, the competent authority does not have to supply examination questions. However, as part of the oversight, the authority must sample check and review the organisations' question data bank and the examination process.
How should the 50% of tasks required for practical training be selected? Should it be 50% of tasks as per glossary (e.g. LOC, FOT, SGH, R/I, etc.)?
The selection of 50% of tasks cannot be selected according to the glossary. Paragraph 3.2 of Appendix III to Part-66 clearly states that ‘the tasks selected shall be representative of the aircraft and systems both in complexity and diversity. In addition, the practical training should particularly address the tasks which cannot be explained by theoretical training only. While relatively simple tasks may be included, other more complex tasks shall also be incorporated and completed as appropriate to the aircraft type.
Regarding the way to read the table in paragraph 3.2, the lines aims at covering the main systems so that no line relevant to the particular aircraft type should be omitted in the selection. Inside each line applicable to the aircraft type, half or more of the crosses can be selected. From a learning point of view, selecting 2 simple tasks as LOC and SGH would not be “representative”, while selecting LOC and TS, for example, would be much more appropriate.
When selecting the tasks, the usage of filtering method based on the criteria similar to that described in AMC to paragraph 3.1(d) of Appendix III to Part-66, point 5 f) is recommended.
Should examiners be specialists in the subjects, or can they be responsible for the proper conduct of the examination without being responsible for the content?
“Examiner” should be here understood as “invigilator” (i.e. the personnel responsible for merely running the examination).
The examiners (invigilators) are not required to be experts in the subjects examined when relative to the MCQs in accordance with Appendix II to Part-66. However, the assessment of essay questions as part of the basic knowledge has to be conducted by knowledgeable personnel with the help of a standard reply. Eventually, the invigilators must be trained to the examination process.
Examiners should demonstrate a clear understanding of the examination standard required by Part-66 and have a responsible attitude to the conduct of examinations such that the highest integrity is ensured. (GM 147.A.105(g)).
Regarding the type training examination and assessment standard as well as type examination standard as described in Part-66, Appendix III, paragraphs 4 and 5, the theoretical element examination can follow the same principle as above; however, for the practical element assessment, the examiner(s) must be appropriately qualified. Further provisions are available in Appendix III to AMC to Part-66.
Should the Part-147 organisation’s quality system be audited?
147.A.130(b) states that the approved Part-147 organisation shall establish a quality system including:
- an independent audit function to monitor training standards, the integrity of knowledge examinations and practical assessments, compliance with and adequacy of the procedures, and
- a feedback system of audit findings to the person(s) and ultimately to the accountable manager referred to in 147.A.105(a) to ensure, as necessary, corrective action.
This means that the quality system itself should be independently audited. The competent authority cannot perform this function on behalf of the organisation.
Within its approved procedures, the organisation has to monitor the quality system’s procedures. This implies that quality system monitoring itself must be subject to internal audits:
- No conflict of interest is allowed - it is not permitted that such a function be performed by quality system’s staff;
- This can be also outsourced;
- The right level of the auditor(s)’ position within the organisation shall be met in order to assure the objective of 147.A.130 (b)2. (e.g. conflict of hierarchy, which could hinder an efficient and transparent report to the accountable manager).
In addition, the audit programme/plan needs to reflect this regulatory aspect.
The EASA Flight Standard Directorate consistently applies that policy during their standardisation visits.
Is it possible to perform aircraft type training in two different organisations? Can I do my practical portion of the type training in a Part-145 organisation?
Only a Part-147 organisation has the privilege (if approved by its competent authority) to provide aircraft type training courses. This comprises both the theoretical and practical element of the aircraft type training, including the related examinations and assessments. This means that the practical element of the aircraft type training shall be completed in a Part-147 organisation.
However, the aircraft type training may be conducted physically in a Part-145 organisation under the control (and as a part of the approval) of a Part-147 organisation issuing the Certificate of Recognition. It is not the privilege of the Part-145 organisation to conduct aircraft type training courses on its own.
In addition, the theoretical and practical element of the aircraft type training can be conducted by two different approved Part-147 organisations. The competent authority endorsing the type rating on the license should be convinced that the interfaces have been correctly addressed before proceeding thereof (66.B.115(b) refers).
In the special case where the aircraft type course is directly approved by the competent authority in accordance with the procedure 66.B.130 (i.e. only on a case by case basis – special authorization not granted for long term periods), the training can be conducted outside the scope of a Part-147 organisation. As a consequence, the certificate issued is not mutually recognized between Member States, which means it can only be used for aircraft type endorsement by the licensing authority who issued that direct approval.
Shall a Part-147 approved organisation have a mandatory occurrence reporting system according to (EU) No.376/2014?
Article 4 of Regulation (EU) No. 376/2014 defines the persons and organisations obliged to report occurrences under the “mandatory reporting system”. Personnel working at/for organisations approved in accordance with EASA Part 147 are not listed in paragraph 6 of article 4, therefore such organisations are not required to implement mandatory/ voluntary reporting systems according to Regulation (EU) No. 376/2014. This does not prevent any organisation or person involved in aviation activities, including maintenance training activities, to report any safety occurrence or other safety information they consider relevant.
Such reports would be to the voluntary reporting system to be established by all competent authorities according to Article 5.2 of Regulation (EU) No. 376/2014.
Typically a Part- 147 approved training organisation having implemented an Safety Management System (SMS) on a voluntary basis would have such a voluntary occurrence reporting system.
The European Commission (EC) published Guidance Material for Regulation EU No. 376/2014. Paragraph 3.3 further elaborates on the organisations affected by that regulation.
An online service developed by the EC allows organisations and individuals to report aviation safety occurrences to aviation authorities.
Is it possible to grant a Part-147 approval to an organisation applying only for basic knowledge training?
Yes, in such case Form 148 shall be used as template for the Certificate of Recognition, which specifies “Basic training course” or “Basic examination”. In the particular case where all modules are not conducted, (see next questions) the certificate shall state only “Basic examination” and the modules conducted be mentioned on the certificate including the date(s) of the examination(s).
Part-147 approved organisations can also give courses outside the scope of Part-66. Can these courses be certified? (e.g. continuation training for the purpose of the certifying staff privileges as required by 145.A.35, task training, NDT, engine run, HF, SMS, etc.)
Courses outside the scope of Part-66 cannot be part of the Approval Schedule of the approved Part-147 organisation. This does not prevent a training organisation to provide such courses. The scope, content and the delivery methods of these courses will not be reviewed by the Agency or the EASA Member States, as part of the audit scope of the Part-147 organisation. However, when Part-M or Part-145 requires the staff to be trained, the appropriateness of such training being delivered would be assessed during the audits of these particular organisations.
What is the maximum number of students attending the examination?
147.A.100(b) defines the facility requirements for the instructions of theory and the conduct of knowledge examinations. Point 1 deals with the facility requirement for knowledge training whereby the number of students shall not exceed 28. Point 2 defines the facility requirements for the examination purposes, where the maximum number of students attending the knowledge examination is not limited. The number of students attending the knowledge examination is indirectly limited only by the size, layout and arrangement of the accommodation in order to fulfil the following requirements:
- … no student can read the paperwork or computer screen of any other student from his/her position during examinations (147.A.100(b)2), and
- Examination candidates shall be separated from each other so that they cannot read each other’s examination papers. (66.B.200(h)).
Consequently, as long as the facility and examination standard as well as the integrity of the examination can be ensured, the number of candidates attending the examination may not be limited. In case of a larger number of candidates, two or more examiners may be used to ensure the integrity of the examination, such as separation of the candidates, no potential cheating, no speaking to each other, only examination paper on the table, no examination paper removed from the room, etc.
What is the minimum duration of the practical element of the aircraft type training?
The duration of the practical training should ensure that the content of training required by paragraph 3.2 of Appendix III to Part-66 is completed. However, for aeroplanes with a MTOM equal or above 30000 kg, AMC to paragraph 1(b) of Appendix III to Part-66 recommends the duration of the practical element of a type rating training course be not less than two weeks, unless a shorter duration meeting the objectives of the training and taking into account pedagogical aspects (maximum duration per day) is justified to the competent authority. This means that the duration of the a/c type practical training is not the main driver as justified by the status of that AMC. According to point 3.2 (b) Appendix III to Part-66 (having the status of requirement), the duration should be based on the content sufficiently representative in diversity and complexity in order to gain the needed competence.
I have completed a part of my basic training course (including some module examinations) in an approved Part-147 organisation. I’m moving to another country and would like to continue my basic training in a Part-147 organisation located in the country where I move in. Is this possible? What will happen with my certificates? Can I get the maximum reduction of the experience required for the Part-66 licence?
There are several scenarios possible depending on the particular case. Here are some most probable cases for category B1 or B2:
Case No 1 (baseline – standard case) : The applicant completes the whole basic knowledge course (including the training, practical assessments and basic modules examinations) in an approved Part-147 maintenance training organisation.
Result: The Certificate of Recognition (CoR) of the basic course completion is issued by the organisation. The applicant can apply for the Part-66 licence with 2 years of maintenance experience.
Case No 2: The applicant completes the basic training in two different Part-147 AMTO (including the examinations).
Result: The CoRs for the successful examination of each individual module are issued (by different AMTO), but not the CoR for the basic course completion. The applicant does not benefit from the experience reduction and have to fulfil the requirement of 3 years of experience (if recognised as skilled worker) or 5 years.
- It may happen that some of the competent authorities would give the complete credit on experience in case the applicant can prove that:the training completed in different organisation covers in total the Appendix I syllabus; and
- all the practical assessments are performed and passed successfully; and
- all interactions between the modules have been correctly addressed; and
- there was a right proportion of theoretical and practical training for each subject.
As this demonstration requires a significant investment, the applicant is invited to directly contact the competent responsible for performing such an investigation.
Case No 3: The applicant has completed a full basic training course in one approved Part-147 organisation. Unfortunately, the candidate was not in a position to successfully pass the full examination process (all modules) in that organisation and had to pass the missing portion of the examination in another approved Part-147 organisation.
Result: In this case the applicant would receive a CoR for basic training only as well as the CoRs related to the modules successfully passed in that approved Part-147 organisation. The examination for the missing modules may be successfully passed in another approved Part-147 organisation(s) with issuance of the related CoRs thereof. The combination of all these CoRs may be sufficient for the competent authority to recognise the training course as successfully “completed” and to grant the maximum credit for the experience (only 2 years needed) for the issue of the license.
Case No 4: The applicant did not attend a Part-147 basic training course but only took examinations in one or more approved Part-147 organisation(s).
Result: The applicant would receive several CoRs for the successful examination of individual modules from one or more approved Part-147 organisations. No credit of experience as per 66.A.30 will be granted (except for skill workers – 3 years). Standard 5 years of experience will be required.
Further information is given in AMC to Appendix III to Part-147 “Certificates of Recognition referred to in Annex IV (Part-147) – EASA Forms 148 and 149.
Does the CAMO quality system need to be subject to monitoring?
Yes, the quality system is part of the activities of the CAMO and therefore it should be monitored.
Point M.A.712(b) requires that the quality system monitors:
- that all CAMO activities are being performed in accordance with the approved procedures, and,
- the continued compliance with requirement of part-M.
The quality system procedures are considered to be within these approved procedures . This implies that quality system must be subject to audits and the CAMO audit programme/plan needs to reflect this.
Besides that the audits to the quality system shall satisfy the requirement of independent audits. This is further explained in AMC M.A.712(b) point 8: the independence of the audits should be established by always ensuring that audits are carried out by personnel not responsible for the functions, procedures or products being checked. So, the quality manager cannot audit the quality system in terms of independence of the audit. Therefore, to audit the quality system, it is acceptable:
- to use competent personnel from a different section/department in the same organisation not responsible for the quality function/procedure, or,
- to contract the independent audit element of the quality system to another organisation or a qualified competent person, or,
- that the quality system is monitored and certified against an internationally recognised quality standards by a certification organisation
The way the quality system is going to be audited has to be described in the CAME and approved by the competent authority.
Can an airworthiness review certificate (ARC)/recommendation be issued after an airworthiness review with open findings?
Neither an ARC nor a recommendation can be issued with open findings. Each finding requires a corrective action before the issue of the ARC or recommendation. The corrective action should be adequate to the open finding and it should be carried out and verified by the airworthiness review staff (ARS) before the issue of the ARC/ recommendation.
Can a part-66 certifying staff perform an airworthiness review on an aircraft in which he or she had released some maintenance?
To avoid compromising the independence of the ARS, he or she should have not been involved in the release to service of the aircraft of which he or she intends to perform the airworthiness review, except on maintenance tasks performed during the physical survey or performed as a result of findings discovered during the physical survey of the airworthiness review (AMC M.A.707 (a)).
Can an extension of an ARC be anticipated more than 30 days?
As long as the conditions established for controlled environment (M.A.901 (b): continuously managed during the previous 12 months by a unique CAMO and maintained for the previous 12 months by part-145/part-M subpart F maintenance organisations or maintenance tasks referred to in point M.A.803(b) carried out and released to service by independent certifying staff (M.A.801(b)2) or pilot owner (M.A.801(b)3) are met, the validity of the ARC can be extended for a period of one year. Should the ARC extension be anticipated more than 30 days, you will lose the continuity of the airworthiness review pattern, being the next date of expiry one year after the date of extension.
Maintenance for each type of aircraft/operation
Licenced air carriers 
Maintenance to be performed by Part-145 organisations
Commercial specialised operations or CAT other than licenced air carriers or commercial ATOs
Complex motor-powered aircraft 
Maintenance to be performed by Part-145 organisations
Other than complex motor-powered aircraft (CMPA)
Maintenance to be performed by:
Other than commercial operations
Maintenance to be performed by part-145 organisations
Other than CMPA and limited operations 
Maintenance may be performed by:
 Licensed air carriers are EU air carriers holding an operating licence in accordance with Regulation (EC) 1008/2008
 Twin turboprop aeroplanes of 5 700 kg MTOM and below can be exempted by the Member State from complying with any requirements applicable to CMPA and shall instead comply with the requirements applicable to other than CMPA.
 Limited operations are defined in Regulation (EU) 1312/2014 Article 2(p)
 Only limited to non-CMPA of 2730 kg MTOM and below
Are deputy nominated persons required in CAMO?
Neither M.A.706 (c) nor M.A.706 (d) contain a specific requirement for the identification of deputy “nominated persons” as in part-145 (145.A.30(b)(4)). So, in principle, we could say that there is no requirement for the nomination or identification of deputy “nominated persons”.
Nevertheless, the CAMO needs to take into account the conditions for the continued validity of the approval contained in M.A.715, in particular point (a)(1) which refers to the continued validity of the approval provided the organisation remains in compliance with the requirements.
The CAMO should ensure that they remain in compliance during the absence of the nominated persons, this could be by identifying in the CAME “one or several deputies” and the conditions under which the deputies will assume the responsibilities (this option could be acceptable for a short/medium absence). Another option would be to nominate another person. This would be necessary when the absence is going to be of considerable length and in this case the nomination and acceptance by the competent authority is done using the Form 4.
Which tasks of the aircraft maintenance programme (AMP) could be the subject to deletion or interval extension by a CAMO using the indirect approval procedures?
The indirect approval procedures may only be used for:
- the tasks, prescribed by the Design Approval Holder (DAH) in accordance with Part-21. The interval of these tasks could be decreased by the CAMO and extended to the values prescribed by the DAH,
- CAMO originated tasks which could be added, deleted or extended,
- addition/deletion/interval extension for the tasks arising from recommendations issued by the DAH.
In any case, such processes still should be based on the M.A.301(4) analysis of the effectiveness of the AMP.
Can the airworthiness review certificate (ARC) of the large aircraft be extended during the extensive maintenance/long term storage?
An ARC extension could be performed as long as:
- the conditions established for controlled environment (M.A.901 (b)) are met. This means:
- continuously managed during the previous 12 months by a unique CAMO, and
- maintained for the previous 12 months by Part 145 organisations.
- there is no evidence or reason to believe that the aircraft is not airworthy, as stated in M.A.901(k).
Thus, the procedure for the extension established in the CAMO has to address verification of the compliance with 3 above mentioned conditions. An aircraft going through the lengthy maintenance/modification or long-term storage is not considered to meet the condition number 2.
Is EASA Forms 1 required during the import of the aircraft in the EU?
For the import of aircraft in the EU, the provisions of M.A.904 require the accomplishment of the airworthiness review, associated AMC M.A.904(a)(2) defines work to be performed in order to determine the airworthiness status of the aircraft.
When performing the airworthiness review there would be certain provisions of part-M where it might be not possible to show the full compliance with M.A.710 e.g. availability of EASA Form 1 for all relevant components. In such case, other releases to service or serviceable tags may be acceptable for the competent authority of the importing country.
Nevertheless, it must be ensured that the information required by M.A.305(d) related to the status of ADs, determination of remaining life, modifications and repairs is available (see also AMC M.A.305(d)).
CAMO 1 uses the anticipation when performing the airworthiness review or extension for 90 or 30 days correspondingly. After the issue or extension of the ARC, the aircraft is transferred during the anticipation period from CAMO 1 to CAMO 2. As the consequence CAMO 2 has solely continuously managed the aircraft for more than 12 months due to the term of the validity of the ARC accordingly being more than 12 month. Are the requirements of the M.A.901(b)(i) satisfied?
The intent of the article M.A.901(b)(i) is to define the ‘controlled environment’ by indicating that the aircraft must be managed during last 12 months by unique CAMO, which indirectly refers to a standard term of validity of the ARC. Therefore, if the aircraft has been managed by more than one CAMO since the date of issue of the last ARC or the date of issue of the ARC extension, it actually indicates that controlled environment was discontinued.
In addition in accordance with M.A.710(d) the 90 days anticipation shall be used to allow the physical review to be performed during a maintenance check. However, the intention of the rule was never to address the transfer of the aircraft within those 90 days with the purpose of avoiding the forthcoming airworthiness review. Concerning the 30 days anticipation for the ARC extension, point M.A.901(f) is intended for 2 consecutive extensions by the same CAMO managing the continuing airworthiness of the aircraft from the date of issue of the ARC, so the extended ARC could not be extended 2nd time by another organisation, because this constitutes a ‘breach’ of controlled environment.
What are the plans of EASA in regards of the guidance relating to components’ Time between overhaul (TBO) extension?
The Decision 2013/025/R of the Executive Director of the Agency of 11 September 2013 "Recommended practice for TBO extension’"was published by EASA in September 2013. Two months later, in December 2013, the ED Decision 2013/034/R cancelled the ED Decision 2013/025/R - "Recommended practice for TBO extension". That was done in reply to implementation difficulties reported by some NAAs. Afterwards EASA has decided to include the guidance related to the extension of the TBO into the framework of the Rulemaking task Part-M GA Task Force (Phase II).
Must the EASA Form 1 be kept for on-condition components ?
There is no specific requirement to retain the EASA Form 1 of such components unless needed to comply with the requirements set forth in M.A.305 (h)(1), (h)(4), (h)(5) and (h)(6) for determining the continuing airworthiness and configuration of the aircraft.
Do the maintenance contracts need to be submitted for the approval to the competent authorities after Commission Regulation (EU) 2015/1536 applies?
M.A.708(c) requires the CAMO to establish a written maintenance contract for CMPA or aircraft used for CAT or commercial specialised operations or commercial ATO operations.
The individual contracts need not to be submitted for approval to the competent authority. The competent authority shall approve the procedures for contracted maintenance as part of the CAME Part 3 and the basic information of the contracted maintenance should be included in a list of contracted maintenance organisations in the CAME part 5.4.
The amendment to the list mentioned in 5.4 may be managed through the indirect approval procedure.
Only for air carriers licenced in accordance with Regulation (EC) 1008/2008, the maintenance contracts need to be submitted to the competent authority as part of the package for initial application or for a change to the Air Operator Certificate as indicated in under M.B.701(a)(4).
When does the interval for the next calendar aircraft maintenance check/task or the calendar interval for the next component check/overhaul starts?
In a normal scenario :
- The date of signing the certificate of release to service (CRS) should be considered the date of the accomplishment.
- The next due date should be calculated using this date.
However, there may be a lot of different considerations that change the normal scenario and make the statements above no longer valid. For example:
Case 1: The interval of the maintenance task has been ‘extended’ using a procedure included in the aircraft maintenance programme and approved by competent authority (refer to Appendix I to AMC M.A.302 point 4). Such procedure is often referred as permitted variation or ’tolerance’. In this case the next due date calculated using the original due date.
Case 2: The maintenance task refers to a component maintenance task, for example the landing gear overhaul. In this case the start of the interval would be the date of the release to service after the overhaul of the landing gear or in some particular cases when specified in the maintenance data the interval may start from the date of installation.
Case 3: The task is part of a maintenance check, where the duration of the check is significant compared to the interval of the task. For example, a check that lasts for 2 months and an inspection that has an interval of 3 months. In this case, it is reasonable to think that the performance of this task would need to be planned for the last days of the maintenance check, when possible. Otherwise, the inspection also can be done on the first day, but in that case, it is reasonable to expect that it will be released the same day (then the next due date would be 3 months after the CRS is signed). It also applies to the specific cases of mandatory tasks (ADs, CMRs, ALIs, etc.) defining repetitive action with a calendar limit.
There are many other examples, the key is to use sound engineering judgment and the guidance provided in the Instructions for Continuing Airworthiness to calculate the next due date.
Continuing airworthiness management for each type of operator/ aircraft
|CONTINUING AIRWORTHINESS MANAGEMENT|
Licenced air carriers 
Continuing airworthiness shall be performed by a CAMO. Operator shall be CAMO approved (CAMO linked to the AOC).
|Commercial specialised operations or CAT operations other than licensed air carriers or commercial ATOs||
Continuing airworthiness shall be performed by a CAMO. Operator shall obtain CAMO approval, or operator shall contract a CAMO
|Other than commercial operations||Complex motor-powered aircraft ||Continuing airworthiness shall be performed by a CAMO. Owner shall contract a CAMO|
|Other than complex motor-powered aircraft (CMPA) and limited operations ||
Continuing airworthiness management may be performed by the owner. CAMO is not required.
 Licenced air carriers are EU air carriers holding an operating licence in accordance with Regulation (EC) 1008/2008
 Twin turboprop aeroplanes of 5 700 kg MTOM and below can be exempted by the Member State from complying with any requirements applicable to CMPA and shall instead comply with the requirements applicable to other than CMPA.
 Limited operations are defined in Regulation (EU) 1312/2014 Article 2(p).
Can an independent certifying staff maintain ELA1 aircraft used for commercial operations (such as ATO)?
No, ELA1 aircraft used for commercial operations cannot be maintained by independent certifying staff because in accordance with M.A.201(i) commercial operations require maintenance release by an organisation (part-M subpart-F or part-145 approved).
What does the term “detailed maintenance records” mean?
“Detailed maintenance records” are those records required to be kept by the owner/operator to be able to determine the continuing airworthiness and configuration of the aircraft in accordance with part-M relevant for future maintenance. These are different from the detailed maintenance records required to be kept by a maintenance organisation as per M.A.614 or 145.A.55(c). Whereas maintenance organisations are required to retain all detailed records to demonstrate that they worked in compliance with their respective requirements, aircraft owners/operators need to retain those records required for assessing the aircraft configuration and the airworthiness of the aircraft and all components installed. ‘Dirty finger prints’ may not need to be transferred from the maintenance organisation to the aircraft owner/operator.
Where the maintenance organisation retains the detailed maintenance records in accordance with 145.A.55(c) and M.A.614, the owner/operator should receive the aircraft release to service of the maintenance performed and all information necessary to determine the aircraft continuing airworthiness and its configuration, which includes references to all:
- References to taskcards,
- Information and substantiating data on modifications,
- Airworthiness directives,
- Information and substantiating data on repaired and non-repaired damage, and measurements relating to defects.
Is there any European requirement to maintain the back-to-birth traceability for any component fitted to an European aircraft?
The term “back to birth” is not used in European regulations. The requirements that apply to a service life-limited component (see definition in AMC M.A.305) are basically stated in M.A.305 (e) and (h). All detailed maintenance records of a maintenance action (e.g. a restoration) must be kept until another maintenance action equivalent in scope (another restoration) is done, but never less than 36 months. Keep in mind that:
- a service life limited component log card must be kept with all the relevant information, so the action should be recorded there, and
- the records showing compliance with other requirements stated in M.A.305, e.g. an airworthiness directive, or any other information that could be affecting the configuration of the aircraft, must be retained too.
Which are the correct statements to be written in block 11 of EASA Form 1 after maintenance?
Appendix II to part-M describes the following 4 permissible entries in block 11 of EASA Form 1:
The meaning of “Inspected/Tested” status is inspected and/or, if applicable, tested as it described in provisions of part-M/part-145. Besides that, block 12 in the EASA Form 1 should contain the detailed information on the status/work described in block 11.
Quality manager for CAMO: Nomination, acceptance, qualification
The quality manager is considered nominated personnel according M.A.706 (c). The minimum qualification and experience requirements are contained in AMC M.A.706.
The nomination of the quality manager shall be performed using the EASA Form 4.
What are the alleviations introduced by M.A.302(h) on the maintenance programme for General Aviation?
In accordance with M.A.302(h), for ELA1 aircraft not involved in commercial operation, the owner, whether he has contracted a CAMO or not [see M.A.201(i)], has the option not to submit the Aircraft Maintenance Programme (AMP) to the competent authority for approval, but instead ‘declare’ an AMP, subject to compliance with the conditions described therein. In this respect, the owner may decide to deviate from the applicable scheduled maintenance recommendations (see also remark below) without the need to justify such deviation(s), but under his/her full responsibility. Such declared AMP does not need to be sent to the competent authority.
In this scenario though, the declared AMP shall not be less restrictive than the ‘Minimum Inspection Programme’ (MIP) referred to in point M.A.302(i).
In addition, such declared AMP shall be reviewed annually and this review can be done either by the person who performs the airworthiness review, during the accomplishment of the airworthiness review, or by a CAMO if contracted to manage the continuing airworthiness of the aircraft [see M.A.302(h)5].
Besides, if during the airworthiness review it is observed that there are discrepancies on the aircraft linked to deficiencies in the content of the maintenance programme, the competent authority shall be informed and the AMP amended.
- In accordance with M.A.302 and in particular M.A.302(h)(3), the AMP, declared or approved, shall in all cases include all the mandatory maintenance/continuing airworthiness requirements, such as repetitive Airworthiness Directives or the Airworthiness Limitation Section (ALS).
- In accordance with Part-M Appendix VIII point (b)(9), the tasks that are part of the annual or 100h check contained in the ‘Minimum Inspection Programme’ do not qualify for pilot-owner maintenance referred to in M.A.803.
Please refer also to AMC M.A.302(e) (maintenance programme template), AMC M.A.302(h), GM M.A.302(h) and AMC M.A.302(i) (content of MIP).
Please refer to Article 2 (point k) of Regulation (EU) 1321/2014 for the definition of ELA1.
Please refer to Article 3 (point i) of Regulation (EU) 216/2008 (Basic Regulation) for the definition of commercial operation.
The agency also advises the owner who intends to transition from conventional to declared AMP to contact the competent authority for their guidance.