M.A.801 Aircraft certificate of release to service

Regulation (EU) 2021/700

(a) Except for aircraft released to service by a maintenance organisation approved in accordance with Annex II (Part-145), the CRS shall be issued in accordance with this Subpart.

(b) No aircraft shall be released to service unless a CRS is issued when all maintenance tasks ordered have been properly carried out. The CRS shall be issued by an authorised certifying staff of the maintenance organisation approved in accordance with Subpart F of this Annex or with Annex Vd (Part-CAO), except for maintenance tasks other than complex maintenance tasks listed in Appendix VII to this Annex where the CRS is issued, alternatively by:

1. independent certifying staff acting in accordance with the requirements laid down in Article 5 of this Regulation;

2. the pilot-owner acting in accordance with point M.A.803 of this Annex.

(c) By derogation from point (b), in case of unforeseen situations, when an aircraft is grounded at a location where no maintenance organisation approved in accordance with this Annex, Annex II (Part-145) or Annex Vd (Part-CAO) and no independent certifying staff are available, the owner may authorise any person, with no less than 3 years of appropriate maintenance experience and holding either a valid ICAO Annex 1 compliant maintenance license for the aircraft type requiring certification or a certifying staff authorisation valid for the work requiring certification issued by an ICAO Annex 6 approved maintenance organisation to maintain the aircraft in accordance with the standards set out in Subpart D of this Annex and release it to service. In that case, the owner shall:

1. obtain and keep in the aircraft records specifying details of the maintenance carried out and of the qualifications of the person issuing the CRS;

2. ensure that any such maintenance is later on verified and a new CRS is issued by an appropriately authorised person referred to in point (b) or an organisation approved in accordance with Subpart F of this Annex, Annex II (Part-145) or Annex Vd (Part-CAO), at the earliest opportunity and in any case within 7 calendar days from the issuance of a CRS by the person authorised by the owner;

3. notify the organisation responsible for the continuing airworthiness management of the aircraft, when contracted, or the competent authority in the absence of such a contract, within 7 days from the issuance of such authorisation.

(d) In case of a release to service in accordance with point (b)(1), the certifying staff may be assisted in performing the maintenance tasks by one or more persons subject to his or her direct and continuous control.

(e) A CRS shall contain at least:

1. basic details of the maintenance carried out;

2. the date on which the maintenance was completed;

3. the identity of the organisation or person issuing the CRS, including, alternatively:

(i) the approval reference of the maintenance organisation and the certifying staff issuing the CRS;

(ii) in the case referred to in point (b)(2), the identity and, where applicable, the licence number of the certifying staff issuing the CRS;

4. the limitations to airworthiness or operations, if any.

(f) By derogation from point (b) and notwithstanding point (g), when the required maintenance cannot be completed, a CRS may be issued with the approved aircraft limitations. In that case, the certificate shall indicate that the maintenance could not be completed, as well as indicate any applicable airworthiness or operations limitations, as part of the information required by point (e)(4).

(g) A CRS shall not be issued in the case of any known non-compliance which endangers flight safety.

AMC M.A.801 Aircraft certificate of release to service after embodiment of a Standard Change or a Standard Repair (SC/SR)

ED Decision 2020/002/R

1. Release to service and eligible persons

Only natural or legal persons entitled to release to service an aircraft after maintenance in accordance with Part-M, Part-145 or Part-CAO are considered as an eligible installer responsible for the embodiment of a SC/SR when in compliance with applicable requirements.

For aircraft where there is no Part-66 licence applicable, the release to service of an aircraft after embodiment of a SC/SR is only possible by holders of an appropriate certifying staff qualification valid in a Member State (national qualification), with the following conditions:

               If the holder signs the release to service on behalf of an Approved Maintenance Organisation (AMO), this is valid for aircraft registered in any Member State.

               If the holder signs the release to service as an independent certifying staff (not on behalf of an AMO), this is only valid for aircraft registered in the Member State responsible for such certifying staff qualification.

Depending on its nature, for certain SCs/SRs, the Certification Specification CS-STAN might restrict the eligibility for the issuance of the release to service to certain persons.

Since the design of the SC/SR does not require specific approval, the natural or legal person releasing the aircraft to service after the embodiment of the change or repair takes the responsibility that the applicable Certification Specifications within CS-STAN are fulfilled while being in compliance with Part-M, Part-145 and/or Part-CAO and not in conflict with TC holders’ data. This includes responsibility in respect of an adequate design, the selection/manufacturing of suitable parts and their identification, documenting the change or repair, generation or amendment of aircraft manuals and instructions as needed, embodiment of the change/repair, releasing the aircraft to service and record-keeping.

2. Parts and appliances to be installed as part of a SC/SR

The design of the parts and appliances to be used in a SC/SR is considered a part of the change/repair, and, therefore, there is no need of a specific design approval. However, it is possible that for a particular SC, these Certification Specifications specifically require the use of parts and appliances that meet a technical standard. In this case, when the parts and appliances require to be authorised as an ETSO article, other articles recognised as equivalent by means of an international safety agreement or grandfathered in accordance with Regulation (EU) No 748/2012 are equally acceptable.

Normally, a SC/SR shall not contain specifically designed parts that should be produced by a production organisation approved in accordance with Part-21 (POA). However, in the case that the change or repair would contain such a part, it should be produced by an approved Production Organisation (POA), and delivered with an EASA Form 1. An arrangement in accordance with 21.A.122(b) is not applicable.

Eligibility for installation of parts and appliances belonging to a SC/SR is subject to compliance with the Part-21 and Part-M, Part-145 and Part-CAO related provisions, and the situation varies depending on the aircraft in/on which the SC/SR is to be embodied, and who the installer is. The need for an EASA Form 1 is addressed in Part-21 and Part-M. Furthermore, Part-M Subpart F, Part-145 and Part-CAO contain provisions (i.e. M.A.603(c), 145.A.42(c) and CAO.A.020(c)) allowing maintenance organisations to fabricate certain parts to be installed in/on the aircraft as part of their maintenance activities.

3. Parts and appliances identification

The parts modified or installed during the embodiment of the SC/SR need to be permanently marked in accordance with Part-21 Subpart Q.

4. Documenting the SC/SR and declaring compliance with the Certification Specifications

In accordance with Part-M, Part-CAO or Part-145 (e.g. AMC M.A.801 (e) and AMC 145.A.50(b)), the legal or natural person responsible for the embodiment of a change or a repair should compile details of the work accomplished. In the case of SCs/SRs, this includes, as necessary, based on its complexity, an engineering file containing drawings, a list of the parts and appliances used for the change or repair, supporting analysis and the results of tests performed or any other evidence suitable to show that the design fulfils the applicable Certification Specifications within CS-STAN together with a statement of compliance and amendments to aircraft manuals, to instructions for continuing airworthiness and to other documents such as aircraft parts list, wiring diagrams, etc., as deemed necessary. EASA Form 123 is prepared for the purpose of documenting the preparation and embodiment of the SC/SR. The aircraft logbook should contain an entry referring to EASA Form 123; both EASA Form 123 and the release to service required after the embodiment of the SC/SR should be signed by the same person.

Form 123 and all the records listed on it should follow elementary principles of controlled documentation, e.g. contain reference number of documents, issue dates, revision numbers, name of persons preparing/releasing the document, etc.

5. Record-keeping

The legal or natural person responsible (see paragraph 1. above) for the embodiment of the change/repair should keep the records generated with the SC/SR as required by Part-M or Part-145 and CS-STAN.

In addition, M.A.305 requires that the aircraft owner (or CAMO, if a contract i.a.w. M.A.201 exists) keeps the status of the changes/repairs embodied in/on the aircraft in order to control the aircraft configuration and manage its continuing airworthiness.

With regard to SCs/SRs, the information provided to the owner or CAMO may be listed in Form 123 and should include, as required, a copy of any modified aircraft manual and/or instructions for continuing airworthiness. All this information should normally be consulted when the aircraft undergoes an airworthiness review, and, therefore, a clear system to record the embodiment of SCs/SRs, which is also easily traceable, would be of help during subsequent aircraft inspections.

6. Instructions for continuing airworthiness

As stipulated in M.A.302, the aircraft owner or CAMO needs to assess if the changes in the instructions for continuing airworthiness of the aircraft require to amend the aircraft maintenance programme and to obtain its approval.

7. Embodiment of more than one SC

The embodiment of two or more related SCs described in Subpart B of CS-STAN is permitted as a single change (the use of one Form 123 only) as long as adequate references to and records of all SCs embodied are captured. Restrictions and limitations of the two (or more) SCs would apply. It is permitted to issue a single release to service containing adequate traceability of all the SCs embodied.

8. Acceptable form to be used to record the embodiment of SCs/SRs

EASA Form 123 — Standard Change/Standard Repair (SC/SR) embodiment record

Form 123 Issue 00

AMC M.A.801(b) Aircraft certificate of release to service

ED Decision 2015/029/R

A certificate of release to service is necessary before flight, at the completion of any defect rectification, whilst the aircraft operates a flight between scheduled maintenance checks.

AMC M.A.801(c) Aircraft certificate of release to service

ED Decision 2020/002/R

AIRCRAFT GROUNDED AT OTHER LOCATIONS

1. ‘3 years of appropriate maintenance experience’ means 3 years working in an aircraft maintenance environment on at least some of the aircraft type systems corresponding to the aircraft endorsed on the aircraft maintenance license or on the certifying staff authorisation that the person holds.

2. ‘Holding the proper qualifications’ means holding either:

(a) a valid ICAO Annex 1 compliant maintenance license for the aircraft type requiring certification, or;

(b) a certifying staff authorisation valid for the work requiring certification, issued by an ICAO Annex 6 approved maintenance organisation.

3. A release in accordance with this paragraph does not affect the controlled environment, in accordance with point (b) of M.A.901, of the aircraft as long as the M.A.801(c)2 recheck and release has been carried out by an approved maintenance organisation.

AMC M.A.801(e) Aircraft certificate of release to service

ED Decision 2020/002/R

1. The aircraft certificate of release to service should contain the following statement:

(a) 'Certifies that the work specified except as otherwise specified was carried out in accordance with Part-M and in respect to that work the aircraft is considered ready for release to service'.

(b) For a Pilot-owner a certificate of release to service should contain the following statement:

‘Certifies that the limited pilot-owner maintenance specified except as otherwise specified was carried out in accordance with Part-M and in respect to that work the aircraft is considered ready for release to service’.

2. The certificate of release to service should relate to the task specified in the manufacturer's or operator's instruction or the aircraft maintenance programme which itself may cross-refer to a manufacturer's/operator's instruction in a maintenance manual, service bulletin etc.

3. The date such maintenance was carried out should include when the maintenance took place relative to any life or overhaul limitation in terms of date/flying hours/cycles/ landings etc., as appropriate.

4. When extensive maintenance has been carried out, it is acceptable for the certificate of release to service to summarise the maintenance so long as there is a unique cross-reference to the work-pack containing full details of maintenance carried out. Dimensional information should be retained in the work-pack record.

5. The person issuing the certificate of release to service should use his normal signature except in the case where a computer release to service system is used. In this latter case the competent authority will need to be satisfied that only the particular person can electronically issue the release to service. One such method of compliance is the use of a magnetic or optical personal card in conjunction with a personal identity number (PIN) known only to the individual, which is keyed into the computer. A certification stamp is optional.

6. At the completion of all maintenance, owners, certifying staff, operators and maintenance organisations should ensure they have a clear, concise, legible record of the work performed.

7. In the case of an M.A.801(b)1 release to service, certifying staff should retain all records necessary to prove that all requirements have been met for the issuance of a certificate of release to service.

AMC M.A.801(f) Aircraft certificate of release to service

ED Decision 2020/002/R

INCOMPLETE MAINTENANCE

1. Being unable to establish full compliance with sub-paragraph M.A.801(b) means that the maintenance required by the aircraft owner, CAO or CAMO could not be completed due either to running out of available aircraft maintenance downtime or because the maintenance data requires a flight to be performed as part of the maintenance, as described in paragraph 4.

2. The aircraft owner, CAO or CAMO is responsible for ensuring that all required maintenance has been carried out before flight. Therefore, an aircraft owner, CAO or CAMO should be informed and agree to the deferment of full compliance with M.A.801(b). The certificate of release to service may then be issued subject to details of the deferment, including the aircraft owner, CAO or CAMO authorisation, being endorsed on the certificate.

3. If a CRS is issued with incomplete maintenance a record should be kept stating what action the mechanic, supervisor and certifying staff should take to bring the matter to the attention of the relevant aircraft owner, CAO or CAMO so that the issue may be discussed and resolved with the aircraft owner, CAO or CAMO.

4. Certain maintenance data issued by the design approval holder (e.g. aircraft maintenance manual (AMM)) require that a maintenance task be performed in flight as a necessary condition to complete the maintenance ordered. Within the aircraft limitations, the person authorised to certify the maintenance per M.A.801 should release the incomplete maintenance before this flight. GM M.A.301(i) describes the relations with the aircraft operator, which retains the responsibility for the MCF. After performing the flight and any additional maintenance necessary to complete the maintenance ordered, a certificate of release to service should be issued in accordance with M.A.801.

AMC M.A.801(g) Aircraft certificate of release to service

ED Decision 2020/002/R

'Endangers flight safety’ means any instance where safe operation could not be assured or which could lead to an unsafe condition. It typically includes, but is not limited to, significant cracking, deformation, corrosion or failure of primary structure, any evidence of burning, electrical arcing, significant hydraulic fluid or fuel leakage and any emergency system or total system failure. An AD overdue for compliance is also considered a hazard to flight safety.

M.A.802 Component certificate of release to service

Regulation (EU) 2021/700

(a) Except for components released to service by a maintenance organisation that is approved in accordance with Annex II (Part-145) and for the cases covered by point (e) of point M.A.502, a CRS shall be issued at the completion of any maintenance work carried out on an aircraft component in accordance with point M.A.502.

(b) The authorised release certificate identified as EASA Form 1 constitutes the component CRS, except when such maintenance on aircraft components has been performed in accordance with point (b) or (d) of point M.A.502 in which case the maintenance is subject to aircraft release procedures in accordance with point M.A.801.

AMC M.A.802 Component certificate of release to service

ED Decision 2019/009/R

The purpose of the EASA Form 1 (see also Appendix II to Part-M) is to release components after manufacture and to release maintenance work carried out on such components under the approval of a competent authority, and to allow components that are removed from one aircraft/component to be fitted to another aircraft/component.

When an approved organisation maintains an aircraft component for use by the organisation, an EASA Form 1 may not be necessary depending upon the organisation’s internal release procedures; however all the information normally required for the EASA Form 1 should be adequately detailed in the certificate of release to service.

M.A.803 Pilot-owner authorisation

Regulation (EU) 2019/1383

(a) To qualify as a Pilot-owner, the person must:

1. hold a valid pilot licence (or equivalent) issued or validated by a Member State for the aircraft type or class rating; and

2. own the aircraft, either as sole or joint owner; that owner must be:

(i) one of the natural persons on the registration form; or

(ii) a member of a non-profit recreational legal entity, where the legal entity is specified on the registration document as owner or operator, and that member is directly involved in the decision making process of the legal entity and designated by that legal entity to carry out Pilot-owner maintenance.

(b) For any other than complex motor-powered aircraft of 2 730 kg MTOM and below, which are not used in CAT operations, in commercial specialised operations or in commercial operations by ATOs or DTOs, the pilot-owner may issue a CRS after having carried out limited pilot-owner maintenance as specified in Appendix VIII to this Annex.

(c) The scope of the limited Pilot-owner maintenance shall be specified in the aircraft maintenance programme referred to in point M.A.302.

(d) The CRS shall be entered in the aircraft continuing airworthiness record system and contain basic details of the maintenance carried out, the maintenance data used, the date on which that maintenance was completed, as well as the identity, the signature and pilot licence number of the pilot-owner issuing such a certificate.

AMC M.A.803 Pilot-owner authorisation

ED Decision 2021/009/R

1. Privately operated means the aircraft is operated pursuant to M.A.201(i).

2. A Pilot-owner may only issue a CRS for maintenance he/she has performed.

3. In the case of a jointly-owned aircraft, the maintenance programme should list:

               The names of all Pilot-owners competent and designated to perform Pilot-owner maintenance in accordance with the basic principles described in Appendix VIII of Part-M. An alternative would be the maintenance programme to contain a procedure to ensure how such a list of competent Pilot-owners should be managed separately and kept current.

               The limited maintenance tasks they may perform.

4. An equivalent valid pilot licence may be any document attesting a pilot qualification recognised by the Member State. It does not have to be necessarily issued by the competent authority, but it should in any case be issued in accordance with the particular Member State’s system. In such a case, the equivalent certificate or qualification number should be used instead of the pilot's licence number for the purpose of the M.A.801(b)(2) (certificate of release to service).

5. Not holding a valid medical examination does not invalidate the pilot licence (or equivalent) required under M.A.803(a)1 for the purpose of the Pilot-owner authorisation.