SMALL ORGANISATIONS

This Guidance Material (GM) provides guidance on how the following small organisations satisfy the intent of Part-145:

(a) Organisations that only employ one person, who carries out the certification function and other functions, and that are approved under Part-145 may use the alternatives provided below limited to the following terms of approval:

               Class A2 Base and line maintenance of aeroplanes of 5 700 kg maximum take-off mass (MTOM) or less (with piston engines only)

               Class A3 Base and line maintenance of single-engined helicopters of 3 175 kg MTOM or less

               Class A4 Aircraft other than A1, A2 and A3 aircraft

               Class B2 Piston engines with maximum output of less than 450 HP

               Class C Components

               Class D1 Non-destructive testing

145.A.30(b): The minimum requirement is for one full-time person who meets the Part-66 requirements for certifying staff and holds the position of ‘accountable manager, safety manager, maintenance engineer and is also certifying staff and, if applicable, airworthiness review staff’. No other person may issue a certificate of release to service and therefore if that person is absent, no maintenance may be released during such absence.

(1) The independent audit element of the compliance monitoring function of point 145.A.200(a)(6) may be subcontracted to an appropriate organisation approved under Part-145 or contracted to a person with appropriate technical knowledge and extensive experience of audits, working under the management system of the organisation, with the agreement of the competent authority.

Note: ‘Full-time’ for the purpose of Part-145 means not less than 35 hrs per week except during vacation periods.

(2) 145.A.35. In the case of an approval based on one person using an independent audit monitoring arrangement as referred to in point (1), the requirement for a record of certifying staff is satisfied by the submission to and acceptance by the competent authority of the MOE. With only one person, the requirement for a separate record of authorisation is unnecessary because the EASA Form 3 certificate defines the authorisation. An appropriate statement, to reflect this situation, should be included in the exposition.

(3) 145.A.200(a)(6). It is the responsibility of the organisation or person referred to in point (1) to make a minimum of two on-site audits every year, and it is the responsibility of this organisation or person to carry out these activities on the basis of one pre-announced visit and one unannounced visit to the maintenance organisation.

It is the responsibility of the Part-145 organisation to ensure that effective implementation of all corrective actions takes place.

(b) Recommended operating procedure for a Part-145 organisation based upon up to 10 persons involved in maintenance.

(1) 145.A.30(b) and 145.A.30(c): The normal minimum requirement is for the employment on a full-time basis of two persons who meet the applicable requirements for certifying staff, whereby one holds the position of ‘maintenance engineer’ and the other holds the position of ‘compliance monitoring engineer’.

Either person can assume the responsibilities of the accountable manager and safety manager provided that they can comply in full with the applicable elements of points 145.A.30(a) and 145.A.30(ca), but the ‘maintenance engineer’ is the certifying person in order to retain the independence of the ‘compliance monitoring engineer’ to carry out audits. Nothing prevents either engineer from undertaking maintenance tasks provided that the ‘maintenance engineer’ issues the certificate of release to service. This ‘maintenance engineer’ may also be nominated as airworthiness review staff to carry out airworthiness reviews and to issue the corresponding airworthiness review certificate for aircraft for which Part-ML applies in accordance with ML.A.903.

The ‘compliance monitoring engineer’ should have similar qualifications and status to the ‘maintenance engineer’ for reasons of credibility, unless he/she has a proven track record in aircraft compliance monitoring, in which case some reduction in the extent of his or her maintenance qualifications may be permitted.

In cases where the competent authority agrees that it is not practical for the organisation to nominate a person responsible for the independent audit of the compliance monitoring function, this element may be arranged in accordance with point (a)(1).

145.A.15 Application for an organisation certificate

Regulation (EU) 2021/1963

(a) An application for a certificate or an amendment to an existing certificate in accordance with this Annex shall be made in a form and manner established by the competent authority, taking into account the applicable requirements of Annex I (Part-M), Annex Vb (Part-ML) and this Annex.

(b) Applicants for an initial certificate pursuant to this Annex shall provide the competent authority with:

1. the results of a pre-audit performed by the organisation against the applicable requirements provided for in Annex I (Part-M), Annex Vb (Part-ML) and this Annex;

2. documentation demonstrating how they will comply with the requirements established in this Regulation.

145.A.30 Personnel requirements

Regulation (EU) 2021/1963

(a) The organisation shall appoint an accountable manager that has corporate authority to ensure that all maintenance activities of the organisation can be financed and carried out in accordance with Regulation (EU) 2018/1139 and its delegated and implementing acts. The accountable manager shall:

1. ensure that all necessary resources are available to accomplish maintenance in accordance with this Annex, Annex I (Part-M) and Annex Vb (Part-ML), as applicable, to support the organisation certificate;

2. establish and promote the safety policy specified in point 145.A.200(a)(2);

3. demonstrate a basic understanding of this Regulation.

Regulation (EU) 2021/1963

(b) The accountable manager shall nominate a person or group of persons representing the management structure for the maintenance functions and with the responsibility to ensure that the organisation works in accordance with the MOE and approved procedures. It shall be made clear in the procedures who deputises for a particular person in the case of lengthy absence of that person.

Regulation (EU) 2021/1963

(c) The accountable manager shall nominate a person or group of persons with the responsibility to manage the compliance monitoring function as part of the management system.

Regulation (EU) 2021/1963

(ca) The accountable manager shall nominate a person or group of persons with the responsibility to manage the development, administration and maintenance of effective safety management processes as part of the management system.

Regulation (EU) 2021/1963

(cb) The person or group of persons nominated in accordance with points (b), (c) and (ca) shall have a responsibility to the accountable manager and direct access to him/her to keep him/her properly informed on compliance and safety matters.

Regulation (EU) 2021/1963

(cc) The person or persons nominated in accordance with points (b), (c) and (ca) shall be able to demonstrate relevant knowledge, background and satisfactory experience related to aircraft or component maintenance and demonstrate a working knowledge of this Regulation.

Regulation (EU) 2021/1963

(d) The organisation shall have a maintenance man-hour plan to ensure it has sufficient and appropriately qualified staff to plan, perform, supervise, inspect and monitor the organisation’s activities in accordance with the terms of approval. In addition, the organisation shall have a procedure to reassess the work intended to be carried out when the actual staff availability is reduced compared to the planned staffing level for a particular work shift or period.

Regulation (EU) 2021/1963

(e) The organisation shall establish and control the competency of the personnel involved in any maintenance, airworthiness reviews, safety management and compliance monitoring in accordance with a procedure and to a standard agreed with the competent authority. In addition to the necessary expertise related to the job function, the competency of the personnel must include an understanding of the application of safety management principles, including human factors and human performance issues, which is appropriate to their function and responsibilities in the organisation.

Regulation (EU) 2018/1142

(f) The organisation shall ensure that personnel who carry out or control a continued-airworthiness non-destructive test of aircraft structures or components, or both, 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 from this point, personnel referred to in point (g), points (h)(1) and (h)(2), qualified in category B1, B3 or L in accordance with Annex III (Part-66), may carry out and/or control colour contrast dye penetrant tests.

Regulation (EU) 2018/1142

(g) Any organisation maintaining aircraft, except where stated otherwise in point (j), shall in the case of aircraft line maintenance, have appropriate aircraft-rated certifying staff qualified as category B1, B2, B2L, B3 and L, as appropriate, in accordance with Annex III (Part-66) and point 145.A.35.

In addition such organisations may also use appropriately task-trained certifying staff holding the privileges set out in points 66.A.20(a)(1) and 66.A.20(a)(3)(ii) and qualified in accordance with Annex III (Part-66) and point 145.A.35 to carry out minor scheduled line maintenance and simple defect rectification. The availability of such certifying staff shall not replace the need for category B1, B2, B2L, B3 and L certifying staff, as appropriate.

Regulation (EU) 2018/1142

(h) Any organisation maintaining aircraft, except where stated otherwise in point (j), shall:

1. in the case of base maintenance of complex motor-powered aircraft, have appropriate aircraft-type-rated certifying staff, qualified as category C in accordance with Annex III (Part-66) and point 145.A.35. In addition, the organisation shall have sufficient aircraft-type-rated staff qualified as category B1 and B2, as appropriate, in accordance with Annex III (Part-66) and point 145.A.35 to support the category C certifying staff.

(i) Category B1 and B2 support staff shall ensure that all relevant tasks or inspections have been carried out to the required standard before the category C certifying staff issues the certificate of release to service.

(ii) The organisation shall maintain a register of any such category B1 and B2 support staff.

(iii) The category C certifying staff shall ensure that compliance with point (i) has been met and that all work required by the customer has been accomplished during the particular base maintenance check or work package, and shall also assess the impact of any work not carried out, with a view to either requiring its accomplishment or agreeing with the operator to defer such work to another specified check or time limit.

2. in the case of base maintenance of aircraft other than complex motor-powered aircraft, have one of the following:

(i) appropriate aircraft-rated certifying staff, qualified as category B1, B2, B2L, B3 and L, as appropriate, in accordance with Annex III (Part-66) and point 145.A.35;

(ii) appropriate aircraft-rated certifying staff, qualified in category C and assisted by support staff, as set out in point 145.A.35(a)(i).

Regulation (EU) 2018/1142

(i) Component certifying staff shall be qualified in accordance with Article 5(6) and point 145.A.35.

Regulation (EU) 2021/1963

(j) By way of derogation from points (g) and (h), in relation to the obligation to comply with Annex III (Part-66), the organisation may use certifying staff and support staff that are qualified in accordance with the following provisions:

1. For base maintenance carried out at a location outside a territory for which a Member State is responsible under the Chicago Convention, the certifying staff and support staff may be qualified in accordance with the national aviation regulations of the State in which the base maintenance facility is located, subject to the conditions specified in Appendix IV to this Annex.

2. For line maintenance carried out at a line station located outside a territory for which a Member State is responsible under the Chicago Convention, the certifying staff may be qualified, subject to the conditions specified in Appendix IV to this Annex, in accordance with the following alternative conditions:

               national aviation regulations of the State in which the line station is located,

               national aviation regulations of the State in which the organisation’s principal place of business is located.

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 pilot on the basis of the flight crew licence held. In that case, the organisation shall ensure that the pilot has carried out sufficient practical training ensuring that the pilot can accomplish the airworthiness directive.

4. If an aircraft is operated away from a supported location, the organisation may issue a limited certification authorisation to the pilot on the basis of the flight crew licence held, subject to being satisfied that the pilot has carried out sufficient practical training ensuring that the pilot can accomplish the specified task.

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 point must be reported to the competent authority within seven days after issuing 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.

Regulation (EU) 2021/1963

(k) If the organisation performs airworthiness reviews and issues the corresponding airworthiness review certificate in accordance with point ML.A.903 of Annex Vb (Part-ML), it shall have airworthiness review staff that are qualified and authorised in accordance with point 145.A.37.

COMPETENCY ASSESSMENT ELEMENTS

An example of elements that may be considered during a competency assessment according to the job functions and the scope, size and complexity of the organisation, is given in the following table (not exhaustive):

Managers

Planners

Supervisor

Certifying staff

and support staff

Mechanics

Specialised

Service staff

Compliance monitoring staff

Safety management personnel

Knowledge of applicable officially recognised standards

 

 

 

 

 

X

X

 

Knowledge of auditing techniques: planning, conducting and reporting

 

 

 

 

 

 

X

X

Knowledge of safety management, human factors, human performance and limitations, and just culture

X

X

X

X

X

X

X

X

Knowledge of logistics processes

X

X

X

 

 

 

 

 

Knowledge of organisation capabilities, privileges and limitations

X

X

X

X

 

X

X

X

Knowledge of Part-M, Part-ML, Part-145 and any other relevant regulations

X

X

X

X

 

 

X

X

Knowledge of relevant parts of the maintenance organisation exposition and procedures

X

X

X

X

X

X

X

X

Knowledge of occurrence reporting (mandatory and voluntary), internal reporting scheme and understanding of the importance of reporting occurrences, incorrect maintenance data and existing or potential defects

X

X

X

X

X

X

 

X

Knowledge of safety risks linked to the working environment

X

X

X

X

X

X

X

X

Knowledge of CDCCL when relevant

X

X

X

X

X

X

X

X

Knowledge of EWIS when relevant

X

X

X

X

X

X

X

X

Understanding of professional integrity, behaviour and attitude towards safety

X

X

X

X

X

X

X

X

Understanding of conditions for ensuring continuing airworthiness of aircraft and components

 

 

 

X

 

 

X

 

Understanding of his or her own human performance and limitations

X

X

X

X

X

X

X

X

Understanding of personnel authorisations and limitations

X

X

X

X

X

X

X

 

Understanding critical maintenance tasks

X

X

X

X

X

 

X

X

Ability to compile and control completed work cards

 

X

X

X

 

 

 

 

Ability to consider human performance and limitations.

X

X

X

X

 

 

X

X

Ability to determine the required qualifications for task performance

 

X

X

X

 

 

 

 

Ability to identify and rectify existing and potential unsafe conditions

X

 

X

X

X

X

X

X

Ability to manage third parties involved in maintenance activity

X

X

X

 

 

 

 

 

Ability to confirm proper accomplishment of maintenance tasks

 

 

X

X

X

X

 

 

Ability to identify and properly plan performance of critical maintenance tasks

 

X

X

X

 

 

 

 

Ability to prioritise tasks and report discrepancies

 

X

X

X

X

 

 

 

Ability to process the work requested by the operator

 

X

X

X

 

 

 

 

Ability to promote the safety policy

X

 

X

 

 

 

 

X

Ability to properly process removed, uninstalled and rejected parts

 

 

X

X

X

X

 

 

Ability to properly record and sign for work accomplished

 

 

X

X

X

X

 

 

Ability to recognise the acceptability of parts to be installed prior to fitment

 

 

X

X

X

 

 

 

Ability to split complex maintenance tasks into clear stages

 

X

X

 

 

 

 

 

Ability to understand work orders, work cards and refer to and use applicable maintenance data

 

X

X

X

X

X

X

 

Ability to use information systems

X

X

X

X

X

X

X

X

Ability to use, control and be familiar with the required tooling and/or equipment

 

 

X

X

X

X

 

 

Adequate communication and literacy skills

X

X

X

X

X

X

X

X

Analytical and proven auditing skills (for example, objectivity, fairness, open-mindedness, determination, …)

 

 

 

 

 

 

X

X

Maintenance error investigation skills

 

 

 

 

 

 

X

X

Resources management and production planning skills

X

X

X

 

 

 

 

 

Teamwork, decision-making and leadership skills

X

 

X

X

 

 

X

X

Ability to encourage a positive safety culture and apply a just culture

X

 

X

 

 

 

X

X

145.A.37 Airworthiness review staff

Regulation (EU) 2021/1963

(a) In order to be approved to carry out airworthiness reviews and to issue the corresponding airworthiness review certificates (ARC) for aircraft covered by Annex Vb (Part-ML), the organisation shall have airworthiness review staff that comply with all of the following requirements:

(1) they have acquired experience in continuing airworthiness of at least 1 year for sailplanes and balloons and of at least 3 years for all other aircraft;

(2) they hold a certifying staff authorisation for the corresponding aircraft;

(3) they have acquired knowledge of Annex I (Part-M), Subpart C, or of Annex Vb (Part-ML), Subpart C;

(4) they have acquired knowledge of the procedures of the maintenance organisation relevant to the airworthiness review and issue of the airworthiness review certificate.

(b) Before the organisation issues an airworthiness review authorisation to a candidate, that person shall perform an airworthiness review under the supervision of the competent authority or under the supervision of a person that is already authorised as airworthiness review staff by the organisation. If this airworthiness review under supervision is satisfactory, the competent authority shall formally accept that person to become airworthiness review staff.

(c) The organisation shall ensure that the airworthiness review staff can demonstrate appropriate recent continuing airworthiness experience.

145.A.42 Components

Regulation (EU) 2021/700

(a) Classification of components. All components shall be classified into the following categories:

(i) Components which are in a satisfactory condition, released on an EASA Form 1 or equivalent and marked in accordance with Subpart Q of Annex I (Part 21) to Regulation (EU) No 748/2012, unless otherwise specified in point 21.A.307 of Annex I (Part 21) to Regulation (EU) No 748/2012, in point M.A.502 of Annex I (Part-M), in point ML.A.502 of Annex III (Part-ML), or in this Annex (Part-145).

(ii)  Unserviceable components which shall be maintained in accordance with this Regulation.

(iii)  Components categorised as unsalvageable because they have reached their mandatory life limitation or contain a non-repairable defect.

(iv)  Standard parts used on an aircraft, engine, propeller or other aircraft component when specified in the maintenance data and accompanied by evidence of conformity traceable to the applicable standard.

(v)  Material, both raw and consumable, used in the course of maintenance when the organisation is satisfied that the material meets the required specification and has appropriate traceability. All material shall be accompanied by documentation clearly relating to the particular material and containing a conformity to specification statement as well as the manufacturing and supplier source.

(b)  Components, standard parts and materials for installation

(i)  The organisation shall establish procedures for the acceptance of components, standard parts and materials for installation to ensure that components, standard parts and materials are in satisfactory condition and meet the applicable requirements of point (a).

(ii)  The organisation shall establish procedures to ensure that components, standard parts and materials shall only be installed on an aircraft or a component when they are in satisfactory condition, meet the applicable requirements of point (a) and the applicable maintenance data specifies the particular component, standard part or material.

(iii)  The organisation may fabricate a restricted range of parts to be used in the course of undergoing work within its own facilities, provided procedures are identified in the exposition.

(iv) Components which are referred to in point (b)(2) of point 21.A.307 of Annex I (Part 21) to Regulation (EU) No 748/2012 shall only be installed if considered eligible for installation by the aircraft owner on their own aircraft.

(c)  Segregation of components

(i)  Unserviceable and unsalvageable components shall be segregated from serviceable components, standards parts and materials.

(ii)  Unsalvageable components shall not be permitted to re-enter the component supply system, unless mandatory life limitation have been extended or a repair solution has been approved in accordance with Regulation (EU) No 748/2012.

145.A.45 Maintenance data

Regulation (EU) 2021/1963

(a) The organisation shall hold and use applicable current maintenance data which is necessary in the performance of maintenance, including modifications and repairs. “Applicable” means relevant to any aircraft, component or process specified in the organisation’s terms of approval and in any associated capability list.

In the case of maintenance data provided by the person or organisation requesting the maintenance, the organisation shall hold such data when the work is in progress, with the exception of the need to comply with point 145.A.55(a)(3).

(b) Applicable maintenance data is the data specified in point M.A.401(b) of Annex I (Part-M) or in point ML.A.401(b) of Annex Vb (Part-ML), as applicable.

(c) The organisation shall establish procedures to ensure that if inaccurate, incomplete or ambiguous procedure, practice, information or maintenance instruction is found in the maintenance data used by maintenance personnel, it is recorded as part of the internal safety reporting scheme referred to in point 145.A.202 and notified to the author of the maintenance data.

(d) The organisation may only modify maintenance instructions in accordance with a procedure that is specified in the MOE. With respect to changes to maintenance instructions, the organisation shall demonstrate that they result in equivalent or improved maintenance standards, and shall inform the author of the maintenance instructions of such changes. For the purposes of this point, “maintenance instructions” mean instructions on how to carry out a particular maintenance task; they exclude the engineering design of repairs and modifications.

(e) The organisation shall provide a common work card or worksheet system to be used throughout the relevant parts of the organisation. In addition, the organisation shall either accurately transcribe the maintenance data referred to in points (b) and (d) onto such work cards or worksheets, or make precise reference to the particular maintenance task or tasks contained in that maintenance data. Work cards and worksheets may be computer generated and held in an electronic database that is adequately protected against unauthorised alteration, and for which there is a backup electronic database which shall be updated within 24 hours after an entry is made to the main electronic database. Complex or long maintenance tasks shall be transcribed onto the work cards or worksheets and subdivided into clear stages to ensure that there is a record of the accomplishment of the complete maintenance task.

When the organisation provides maintenance services to an aircraft operator which requires its own work card or worksheet system to be used, then such work card or worksheet system may be used. In that case, the organisation shall establish a procedure to ensure that those work cards or worksheets are correctly completed.

(f) The organisation shall ensure that all applicable maintenance data is readily available for use when required by maintenance personnel.

(g) The organisation shall establish a procedure to ensure that maintenance data it controls is kept up to date. In the case of operator/customer controlled and provided maintenance data, the organisation shall be able to show that either it has written confirmation from the operator/customer that all such maintenance data is up to date or it has work orders specifying the amendment status of the maintenance data to be used or it can show that it is on the operator/customer maintenance data amendment list.

145.A.48 Performance of maintenance

Regulation (EU) 2021/1963

(a) The organisation may only carry out maintenance on an aircraft or component for which it is approved when all the necessary facilities, equipment, tooling, material, maintenance data and personnel are available.

(b) The organisation shall be responsible for the maintenance that is performed within the scope of its approval.

(c) The organisation shall ensure that:

(1) after the completion of the maintenance, a general verification is carried out to ensure that the aircraft or component is clear of all tools, equipment and any extraneous parts or material, and that all access panels that were removed have been refitted;

(2) an error-capturing method is implemented after the performance of any critical maintenance task;

(3) the risk of errors during maintenance and the risk of errors being repeated in identical maintenance tasks are minimised;

(4) damage is assessed, and modifications and repairs are carried out using the data specified in point M.A.304 of Annex I (Part-M) or point ML.A.304 of Annex Vb (Part-ML), as applicable;

(5) the assessment of aircraft defects is carried out in accordance with point M.A.403(b) of Annex I (Part-M) or ML.A.403(b) of Annex Vb (Part-ML), as applicable.

145.A.50 Certification of maintenance

Regulation (EU) 2021/1963

(a) A certificate of release to service shall be issued by appropriately authorised certifying staff on behalf of the organisation when that certifying staff has verified that all the maintenance that was ordered has been properly carried out by the organisation in accordance with the procedures specified in point 145.A.70, taking into account the availability and use of the maintenance data specified in point 145.A.45, and that there are no known non-compliances which endanger flight safety.

(b) A certificate of release to service shall be issued before flight at the completion of any maintenance.

(c) New defects or incomplete maintenance work orders identified during the maintenance shall be brought to the attention of the person or organisation responsible for the aircraft continuing airworthiness for the specific purpose of obtaining agreement to rectify such defects or completing the missing elements of the maintenance work order. In the case where that person or organisation declines to have such maintenance carried out under this point, point (e) is applicable.

(d) A certificate of release to service shall be issued by appropriately authorised certifying staff on behalf of the organisation after the maintenance that was ordered has been carried out on a component whilst it was off the aircraft. The authorised release certificate “EASA Form 1” referred to in Appendix II of Annex I (Part-M) constitutes the component certificate of release to service except if otherwise specified in point M.A.502 of Annex I (Part-M) or ML.A.502 of Annex Vb (Part-ML), as applicable. When an organisation maintains a component for its own use, the EASA Form 1 may not be necessary if the organisation’s internal release procedures in its MOE so provides.

(e) By derogation to point (a), when the organisation is unable to complete all maintenance ordered, it may issue a certificate of release to service within the approved aircraft limitations. The organisation shall enter such fact in the aircraft certificate of release to service before the issue of such certificate.

(f) By way of derogation from point 145.A.50(a) and point 145.A.42, when an aircraft is grounded at a location other than the main line station or main maintenance base due to the non-availability of a component with the appropriate release certificate, the organisation contracted for the maintenance of that aircraft may temporarily fit a component without the appropriate release certificate for a maximum of 30 flight hours or until the aircraft first returns to the main line station or main maintenance base, whichever is the sooner, subject to the agreement of the person or organisation responsible for the aircraft’s continuing airworthiness and subject to that component having a suitable release certificate but otherwise in compliance with all applicable maintenance and operational requirements. Such components shall be removed by the time limit provided for in the first sentence of this point unless an appropriate release certificate has been obtained in the meantime under points 145.A.50(a) and 145.A.42.

AMC 145.A.50 Certification of maintenance after embodiment of a Standard Change or Standard Repair (SC/SR)

ED Decision 2020/002/R

AMC M.A.801 of the AMC to Part-M and AMC1 ML.A.801 of the AMC to Part-ML contain acceptable means of compliance for the release to service of a SC/SR by an organisation approved in accordance with Part-145.

145.A.55 Record-keeping

Regulation (EU) 2021/1963

(a) Maintenance records

(1) The organisation shall record the details of the maintenance work that is carried out within the scope of its approval. As a minimum, the organisation shall retain all the records that are necessary to prove that all the requirements have been met for the issue of the certificate of release to service, including, if any, subcontractor's release documents.

(2) The organisation shall provide a copy of each certificate of release to service to the operator or customer, together with copies of the detailed maintenance records that are associated with the work carried out and that are necessary to demonstrate compliance with point M.A.305 of Annex I (Part-M) or ML.A.305 of Annex Vb (Part-ML), as applicable.

(3) The organisation shall retain a copy of all detailed maintenance records (including certificates of release to service) and of any associated maintenance data for 3 years from the date when the aircraft or component to which the work relates was issued with a certificate of release to service.

(4) If an organisation terminates its operation, it shall transfer all the retained maintenance records that cover the last 3 years to the last customer or owner of the respective aircraft or component, or shall store them in the manner specified by the competent authority.

(b) Airworthiness review records

(1) If an organisation has the privilege referred to in point 145.A.75(f), it shall retain a copy of each airworthiness review certificate that it has issued, together with all the supporting documents, and shall make those records available, upon request, to the owner of the aircraft.

(2) The organisation shall retain a copy of all the records referred to in point (1) for 3 years after the issue of the airworthiness review certificate.

(3) If an organisation terminates its operation, it shall transfer all the retained airworthiness review records that cover the last 3 years to the last owner or operator of the respective aircraft, or shall store them in the manner specified by the competent authority.

(c) Management system, contracting and subcontracting records

The organisation shall ensure that the following records are retained for a minimum period of 5 years:

(i) records of management system key processes referred to in point 145.A.200;

(ii) contracts, both for contracting and subcontracting, referred to in point 145.A.205.

(d) Personnel records

(1) The organisation shall ensure that the following records are retained:

(i) records of the qualifications, training and experience of the personnel involved in maintenance, compliance monitoring and safety management;

(ii) records of the qualifications, training and experience of all airworthiness review staff.

(2) The records of all airworthiness review staff shall include details of any appropriate qualifications held, together with a summary of their relevant continuing airworthiness experience and training, and a copy of the airworthiness review authorisation issued to that staff by the organisation.

(3) The records of all the certifying staff and support staff shall include the following:

(i) the details of any aircraft maintenance licence held under Annex III (Part-66) or equivalent;

(ii) the scope of the certification authorisations that were issued to that staff, where relevant;

(iii) the particulars of the staff that held limited or one-off certification authorisations referred to in point 145.A.30(j).

(4) Personnel records shall be kept for as long as a person works for the organisation, and shall be retained for at least 3 years after the person has left the organisation, or after an authorisation issued to that person has been withdrawn.

(5) The organisation shall give to the staff referred to in points (2) and (3), upon their request, access to their personnel records as detailed in those points. In addition, upon their request, the maintenance organisation shall furnish each of them with a copy of their personnel records on leaving the organisation.

(e) The organisation shall establish a record-keeping system that allows adequate storage and reliable traceability of all its activities.

(f) The format of the records shall be specified in the organisation’s procedures.

(g) The records shall be stored in a manner that ensures that they are protected from damage, alteration and theft.

RECORDS OF AIRWORTHINESS REVIEW STAFF

The following minimum information, as applicable, should be kept on record in respect of each airworthiness review staff:

(a) Name;

(b) Date of birth;

(c) Certifying staff authorisation;

(d) Experience as certifying staff on aircraft covered by Part-ML;

(e) Qualifications relevant to the approval (knowledge of relevant parts of Part-ML, and knowledge of the relevant airworthiness review procedures);

(f) Scope of the airworthiness review authorisation and personal authorisation reference;

(g) Date of the first issue of the airworthiness review authorisation; and

(h) Expiry date of the airworthiness review authorisation (if appropriate).

145.A.60 Occurrence reporting

Regulation (EU) 2021/1963

(a) As part of its management system, the organisation shall establish and maintain an occurrence-reporting system, including mandatory and voluntary reporting. For organisations that have their principal place of business in a Member State, a single system may be established to meet the requirements of Regulation (EU) No 376/2014 and its implementing acts and of Regulation (EU) 2018/1139 and its delegated and implementing acts.

(b) The organisation shall report to its competent authority and to the design approval holder of the aircraft or component any safety-related event or condition of an aircraft or component identified by the organisation which endangers or, if not corrected or addressed, could endanger an aircraft, its occupants or any other person, and in particular any accident or serious incident.

(c) The organisation shall also report any such event or condition that affects an aircraft to the person or organisation that is responsible for the continuing airworthiness of that aircraft in accordance with point M.A.201 of Annex I (Part-M) or point ML.A.201 Annex Vb (Part-ML), as applicable. For events or conditions that affect aircraft components, the organisation shall report to the person or organisation that requested the maintenance.

(d) For organisations that do not have their principal place of business in a Member State:

(1) the initial mandatory reports shall:

(i) appropriately safeguard the confidentiality of the identity of the reporter and of the persons mentioned in the report;

(ii) be made as soon as practicable, but in any case within 72 hours after the organisation has become aware of the occurrence unless exceptional circumstances prevent this;

(iii) be made in a form and manner established by the competent authority;

(iv) contain all pertinent information about the condition known to the organisation;

(2) where relevant, a follow-up report that provides details of the actions the organisation intends to take to prevent similar occurrences in the future shall be made as soon as those actions have been identified; those follow-up reports shall:

(i) be sent to the entities referred to in points (b) and (c) to which the initial report was sent;

(ii) be made in a form and manner established by the competent authority.

145.A.65 Maintenance procedures

Regulation (EU) 2021/1963

(a) The organisation shall establish procedures which ensure that human factors and good maintenance practices are taken into account during maintenance, including subcontracted activities, and which comply with the applicable requirements of this Annex, Annex I (Part-M) and Annex Vb (Part-ML). Such procedures shall be agreed with the competent authority.

(b) The maintenance procedures established under this point shall:

(1) ensure that a clear maintenance work order or contract has been agreed between the organisation and the person or organisation that requests the maintenance, to clearly establish the maintenance to be carried out so that the aircraft and components may be released to service in accordance with point 145.A.50;

(2) cover all the aspects of carrying out the maintenance, including the provision and control of specialised services, and lay down the standards according to which the organisation intends to work.

145.A.70 Maintenance organisation exposition (MOE)

Regulation (EU) 2021/1963

(a) The organisation shall establish and maintain a maintenance organisation exposition (MOE) that includes, directly or by reference, all of the following:

(1) a statement signed by the accountable manager confirming that the maintenance organisation will at all times work in accordance with this Annex, Annex I (Part-M) and Annex Vb (Part-ML), as applicable, and with the approved MOE. If the accountable manager is not the chief executive officer of the organisation, then the chief executive officer shall countersign the statement;

(2) the organisation’s safety policy and the related safety objectives referred to in point 145.A.200(a)(2);

(3) the title(s) and name(s) of the person(s) nominated under points 145.A.30(b), (c) and (ca);

(4) the duties and responsibilities of the persons nominated under points 145.A.30(b), (c) and (ca), including the matters on which they may deal directly with the competent authority on behalf of the organisation;

(5) an organisation chart showing the accountability and associated lines of responsibility, established in accordance with point 145.A.200(a)(1), between all the persons referred to in points 145.A.30(a), (b), (c) and (ca);

(6) a list of the certifying staff and, if applicable, support staff and airworthiness review staff with their scope of authorisation;

(7) a general description of the manpower resources and of the system that is in place to plan the availability of staff, as required by point 145.A.30(d);

(8) a general description of the facilities at each approved location;

(9) a specification of the scope of work of the organisation that is relevant to the terms of approval as required by point 145.A.20;

(10) the procedure that sets out the scope of changes not requiring prior approval and that describes how such changes will be managed and notified to the competent authority, as required by point 145.A.85(c);

(11) the procedure for amending the MOE;

(12) the procedures specifying how the organisation ensures compliance with this Annex;

(13) a list of the commercial operators to which the organisation provides regular aircraft maintenance services, and the associated procedures;

(14) where applicable, a list of the subcontracted organisations referred to in point 145.A.75(b);

(15) a list of the approved locations including, where applicable, line maintenance locations referred to in point 145.A.75(d);

(16) a list of the contracted organisations;

(17) a list of the currently approved alternative means of compliance used by the organisation.

(b) The initial issue of the MOE shall be approved by the competent authority. It shall be amended as necessary so that it remains an up-to-date description of the organisation.

(c) Amendments to the MOE shall be managed as set out in the procedures referred to in points (a)(10) and (a)(11). Any amendments that are not included in the scope of the procedure referred to in point (a)(10), as well as any amendments related to the changes listed in point 145.A.85(a), shall be approved by the competent authority.

GM1 145.A.70 Maintenance organisation exposition (MOE)

ED Decision 2022/011/R

1. The purpose of the MOE is to:

               specify the scope of work and show how the organisation intends to comply with this Annex; and

               provide all the necessary information and procedures for the personnel of the organisation to perform their duties.

2. Complying with its contents will ensure that the organisation remains in compliance with Part-145 and, as applicable, Part-M and/or Part-ML.

ACCOUNTABLE MANAGER STATEMENT

Part 1 of the MOE should include a statement signed by the accountable manager (and countersigned by the chief executive officer, if different), confirming that the MOE and any associated manuals will be complied with at all times.

The accountable manager’s exposition statement as specified under point 145.A.70(a)(1) should embrace the intent of the following paragraph, and in fact, this statement may be used without amendment. Any modification to the statement should not alter the intent.

‘This exposition and any associated referenced manuals define the organisation and procedures upon which the Part-145 approval certificate is issued by (competent authority*).

These procedures are endorsed by the undersigned and must be complied with, as applicable, when contracts or work orders are being progressed under the organisation approval certificate.

These procedures do not override the necessity of complying with any new or amended regulation published from time to time where these new or amended regulations are in conflict with these procedures.

It is understood that the approval of the organisation is based on the continuous compliance of the organisation with Part-145, Part-M and Part-ML, as applicable, and with the organisation’s procedures described in this exposition. The competent authority* is entitled to limit, suspend, or revoke the approval certificate if the organisation fails to fulfil the obligations imposed by Part-145, Part-M and Part-ML, as applicable, or any conditions according to which the approval was issued.

Signed ........................................

Dated ..........................................

Accountable Manager and...... (quote position)........................

Chief Executive Officer …

For and on behalf of........ (quote organisation’s name)..................................................’

Note: Where it states (‘competent authority*’), please insert the actual name of the competent authority, for example, EASA, the LBA, the DGAC, etc.

Whenever the accountable manager changes, it is important that the new accountable manager signs the statement at the earliest opportunity.

145.A.75 Privileges of the organisation

Regulation (EU) 2021/1963

In accordance with the MOE, the organisation shall be entitled to carry out the following tasks:

(a) maintain any aircraft or component for which it is approved at the locations identified in the certificate and in the MOE;

(b) arrange for the maintenance of any aircraft or component for which it is approved at another subcontracted organisation that works under the management system of the organisation. This is limited to the work permitted under the procedures established in accordance with point 145.A.65 and it shall not include a base maintenance check of an aircraft, or a complete workshop maintenance check or overhaul of an engine or an engine module;

(c) Maintain any aircraft or any component for which it is approved at any location subject to the need for such maintenance arising either from the unserviceability of the aircraft or from the necessity of supporting occasional line maintenance, subject to the conditions specified in the exposition;

(d) Maintain any aircraft and/or component for which it is approved at a location identified as a line maintenance location capable of supporting minor maintenance and only if the organisation exposition both permits such activity and lists such locations;

(e) Issue certificates of release to service in respect of completion of maintenance in accordance with point 145.A.50;

(f) if specifically approved to do so for aircraft covered by Annex Vb (Part-ML) and if it has its principal place of business in one of the Member States, the organisation may perform airworthiness reviews and issue the corresponding airworthiness review certificates under the conditions specified in point ML.A.903 of Annex Vb (Part-ML).