Welcome

Dear GA community,

I want to bring your attention about portable fire extinguishers that need to be located in NCO aircraft (airplane and helicopter). Based on articles "NCO.IDE.A.160 Hand fire extinguishers" and "NCO.IDE.H.160 Hand fire extinguishers" of Regulation (EU) No 965/2012 (Air Ops), NCO operators (except ELA 2 airplane and helicopter) are required to install at least 1 hand fire extinguishers:
(1) in the flight crew compartment; and
(2) in each passenger compartment that is separate from the flight crew compartment, except if the compartment is readily accessible to the flight crew.

In the meantime EASA does not clearly defines what types of fire extinguishing agents are acceptable to be used in aircraft. The only regulation I found is Regulation (EU) 2015/640 (Part-26 - "26.170 Fire extinguishers" - https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:02015R064…) which states that large airplane and helicopter shall not use halon as an extinguishing agent if the first individual certificate of airworthiness is issued on or after 18 May 2019.

Alternatively, I found FAA's "Advisory Circular 20-42D (Hand Fire Extinguishers for use in Aircraft - https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_20-42D.p…)" which clearly states and recommends types of extinguishing agents allowed to be used in aircraft.

In general, ICAO's Annex 6, Part II (International General Aviation Operations) states that:

"2.4.2.3 Any agent used in a built-in fire extinguisher for each lavatory disposal receptacle for towels, paper or waste in
an aeroplane for which the individual certificate of airworthiness is first issued on or after 31 December 2011 and any
extinguishing agent used in a portable fire extinguisher in an aeroplane for which the individual certificate of airworthiness is
first issued on or after 31 December 2018 shall:
a) meet the applicable minimum performance requirements of the State of Registry; and
b) not be of a type listed in the 1987 Montreal Protocol on Substances that Deplete the Ozone Layer as it appears in the
Eighth Edition of the Handbook for the Montreal Protocol on Substances that Deplete the Ozone Layer, Annex A,
Group II.
Note.— Information concerning extinguishing agents is contained in the UNEP Halons Technical Options Committee
Technical Note No. 1 — New Technology Halon Alternatives and FAA Report No. DOT/FAA/AR-99-63, Options to the
Use of Halons for Aircraft Fire Suppression Systems."

I wonder to get to know practice you follow when determining whether certain type of extinguishing agent is suitable for aircraft use or not.

Thank you your attention for this matter!

Topic: National CAA interpretation of Part DTO.GEN.210 (a)(2)

We have in a DTO experienced our national CAA requiring the appointment of a temporary HoT substituting the ordinary HoT in order to continue flight training operations due to the latter having knee surgery. The CAA references AMC 1 to the mentioned rule as the rationale for this decision.

Since this AMC deals with the competence and experience required to be suitable for appointment to the role of HoT, it seems a bit fare fetched to interpret the ”acceptable means” of holding an unrestricted instructor certificate as implying that a temporary unfit situation during a pre-planned period, not affecting mental or managerial abilities, would disqualify the HoT from fulfilling his responsibilities during that period.

Indeed it seems that, would such an interpretation be relevant, then all HoT :s must also stay current on all ratings, and classes their DTOs or ATOs provide training for. Surely not the case is it?

My questions are:
Has any other CAA:s (than Sweden) made a similar interpretation? Is there any other EASA guidelines apart from the AMC that may be referenced?

Hello and a happy new year to everyone!

I've got a question about how to deal with a new kind of ICAs, affecting every airline operating e-enabled aircraft.

OEMs are providing Aircraft Security Operator Guidance (ASOG) (e.g., Security Handbook or (U)ANSOG) to operators to ensure the safe operation of the aircraft. These documents - or to be more precise: the contained instructions - are categorized as ICAs (Instructions for Continued Airworthiness). Usually, it is the responsibility of CAMO to ensure all ICAs are taken care of.
The topics addressed in, and tasks required by the ASOGs are exceeding the common CAMO scope, reaching into areas of others responsibility (e.g., Flight Ops for Crew Processes and Procedures), IT for Digital Certificate management). The instructions are written, following the form of "The operator shall" or "xyz shall be ensured...".
EUROCAE ED-204A is recommending, operators are having an "Aircraft Information Security Center" (AISC) with trained specialists, "acting as the operator's point of contact for aircraft information security events".

Has anyone any experience or is willing to share his/her thoughts about how this could be implemented? Thinking of actions falling into the area and responsibility of others: Does each such tasks need to be interpreted as "subcontracted continuing airworthiness management tasks" (SCAMT)? Is there any more efficient, but regulatory wise acceptable, way to manage this kind of new type of ICAs?

Thank you very much in advance and with kind regards.

This is my opinion the correct way of understanding. read carefully.:

a CAMO (Continuing Airworthiness Management Organization) does not have the privilege to decide on the applicability or status of an Airworthiness Directive (AD). The applicability of an AD is determined solely by the airworthiness authority that issued it (such as EASA, the FAA, or other regulatory agencies).

The Role of a CAMO
Ensuring Compliance:
A CAMO is responsible for managing the continuing airworthiness of aircraft, which includes ensuring compliance with all applicable ADs. They are tasked with:

Identifying applicable ADs for the aircraft under their management.
Ensuring that the corrective actions specified in the AD are carried out within the prescribed timelines.
Applicability of ADs:
The decision about whether an AD applies to a particular aircraft, component, or system is not made by the CAMO. It is based on:

The aircraft type and serial number.
Specific criteria outlined in the AD itself (e.g., affected components, configurations, operational conditions).
Assessment and Recommendations:
While CAMOs do not decide on the applicability of ADs, they may:

Review the ADs to determine their relevance to the managed aircraft.
Consult with the Competent Authority (e.g., EASA or the State of Registry) for clarification if there is ambiguity.
Propose solutions to achieve compliance.
Regulation and Legal Framework
In Europe, under EASA Part-CAMO (Annex Vc to Regulation (EU) 1321/2014), CAMOs are explicitly required to ensure compliance with ADs, but they do not have the authority to determine their applicability independently.

The responsibility to issue and enforce ADs remains with the airworthiness authorities like EASA or the FAA.

In Summary:
A CAMO cannot decide whether an AD applies or not.
Their role is to ensure proper identification and compliance with applicable ADs as required by the regulations.
If there are questions regarding the applicability of an AD, the matter should be clarified with the Competent Authority (e.g., EASA).

Hello

Dear community members,
Our current CAMO policy is that all ADs are received and assessed by CAMO Engineering personnel. Then if AD is considered as not applicable for whatever reason, CAMO Engineering personnel declared it as not applicable in maintenance information system (computerized software). But some of our consultants say that all ADs even it is clear that it is not applicable have to be reviewed and certified by a licensed engineer of contracted AMO (Part-145 organisation). They say that CAMO staff does not have the privileges to evaluate the AD and make a final decision on the status of the AD.
Could you please let us know your position on this? Is this statement is correct?

Dear community members,

We would like to seek your assistance with a research project on aviation maintenance safety we are conducting in the University of Limerick (with our partners from Greece and Australia).

We are exploring the associations between personality traits and human error predisposition, by gauging the experience of aviation maintenance professionals around the world.

If you are working in aviation maintenance it would be greatly appreciated if you could fill in the survey questionnaire and/or share this with anyone who might wish to assist:

Survey Link: https://unioflimerick.eu.qualtrics.com/jfe/form/SV_egSlG7YnUNQkhcW

Thank you in advance for the help.

Kyriakos Kourousis
Associate Professor, University of Limerick