Easy Access Rules for Continuing Airworthiness (Regulation (EU) No 1321/2014)

ED Decision 2020/002/R

1.Maintenance contracts

The following paragraphs are not intended to provide a standard maintenance contract, but to provide a list of the main points that should be addressed, when applicable, in a maintenance contract between the CAMO managing aircraft subject to Part-M and a maintenance organization approved in accordance with Part-145 or Subpart F of Part M. The following paragraphs only address technical matters and exclude matters such as costs, delay, warranty, etc.

When maintenance is contracted to more than one maintenance organisation (for example, aircraft base maintenance to X, engine maintenance to Y, and line maintenance to Z1, Z2 and Z3), attention should be paid to the consistency of the different maintenance contracts.

A maintenance contract is not normally intended to provide appropriate detailed work instructions to personnel. Accordingly, there should be established organisational responsibilities, procedures and routines in the CAMO and the maintenance organisation to cover these functions in a satisfactory way such that any person involved is informed about his/her responsibilities and the procedures that apply. These procedures and routines can be included/appended to the CAME and to the maintenance organisation’s manual/MOE, or can consist in separate procedures. In other words, procedures and routines should reflect the conditions of the contract.

2.Aircraft/engine maintenance

The following subparagraphs may be adapted to a maintenance contract that applies to aircraft base maintenance, aircraft line maintenance, and engine maintenance.

Aircraft maintenance also includes the maintenance of the engines and APU while they are installed on the aircraft.

2.1.Scope of work

The type of maintenance to be performed by the maintenance organisation should be specified unambiguously. In case of line and/or base maintenance, the contract should specify the aircraft type and, preferably, should include the aircraft’s registrations.

In case of engine maintenance, the contract should specify the engine type.

2.2.Locations identified for the performance of maintenance/certificates held

The place(s) where base, line or engine maintenance, as applicable, will be performed should be specified. The certificate held by the maintenance organisation at the place(s) where maintenance will be performed should be referred to in the contract. If necessary, the contract may address the possibility of performing maintenance at any location subject to the need for such maintenance arising either from the unserviceability of the aircraft or from the necessity to support occasional line maintenance.

2.3.Subcontracting

The maintenance contract should specify under which conditions the maintenance organisation may subcontract tasks to a third party (regardless if this third party is approved or not). At least the contract should make reference to M.A.615 and 145.A.75. Additional guidance is provided by the associated AMC/GM. In addition, the CAMO may require the maintenance organisation to obtain the CAMO approval before subcontracting to a third party. Access should be given to the CAMO to any information (especially the quality monitoring information) about the maintenance organisation’s subcontractors involved in the contract. It should, however, be noted that under the CAMO responsibility both the CAMO and its competent authority are entitled to be fully informed about subcontracting, although the competent authority will normally only be concerned with aircraft, engine and APU subcontracting.

2.4.Maintenance programme

The maintenance programme, under which maintenance has to be performed, has to be specified.

The CAMO should have that maintenance programme approved by its competent authority.

2.5.Quality monitoring

The terms of the contract should include a provision allowing the CAMO to perform a quality surveillance (including audits) of the maintenance organisation. The maintenance contract should specify how the results of the quality surveillance are taken into account by the maintenance organisation (see also paragraph 2.22. ‘Meetings’).

2.6.Competent authority involvement

The contract should identify the competent authority(ies) responsible for the oversight of the aircraft, the operator, the CAMO, and the maintenance organisation. Additionally, the contract should allow competent authority(ies) access to the maintenance organisation.

2.7.Maintenance data

The contract should specify the maintenance data and any other manual required for the fulfilment of the contract, and how these data and manuals are made available and kept current (regardless if they are provided by the CAMO or by the maintenance organisation).

This may include but is not limited to:

maintenance programme,

airworthiness directives,

major repairs/modification data,

aircraft maintenance manual,

aircraft illustrated parts catalogue (IPC),

wiring diagrams,

troubleshooting manual,

Minimum Equipment List (normally on board the aircraft),

operator’s manual,

flight manual,

engine maintenance manual,

engine overhaul manual.

2.8.Incoming conditions

The contract should specify in which condition the aircraft should be made available to the maintenance organisation. For extensive maintenance, it may be beneficial that a work scope planning meeting be organised so that the tasks to be performed may be commonly agreed (see also paragraph 2.23 ‘Meetings’).

2.9.Airworthiness directives and service bulletins/modifications

The contract should specify the information that the CAMO is responsible to provide to the maintenance organisation, such as:

the status of the ADs including due date and the selected means of compliance, if applicable; and

status of modifications and the decision to embody a modification or an SB.

In addition, the contract should specify the type of information the CAMO will need in return to complete the control of ADs and modification status.

2.10.Hours and cycles control

Hours and cycles control is the responsibility of the CAMO, and the contract should specify how the CAMO should provide the current hours and cycles to the maintenance organisation and whether the maintenance organisation should receive the current flight hours and cycles on a regular basis so that it may update the records for its own planning functions (see also paragraph 2.22 ‘Exchange of information’).

2.11.Life-limited parts and time-controlled components

The control of life-limited parts and time-controlled components is the responsibility of the CAMO. The contract should specify whether the CAMO should provide the status of life-limited parts and timecontrolled components to the maintenance organisation, and the information that the approved organisation will have to provide to the CAMO about the removal/installation of the life-limited parts and time-controlled components removal/installation so that the CAMO may update its records (see also paragraph 2.22 ‘Exchange of information’).

2.12.Supply of parts

The contract should specify whether a particular type of material or component is supplied by the CAMO or by the maintenance organisation, which type of component is pooled, etc. The contract should clearly state that it is the maintenance organisation’s responsibility to be in any case satisfied that the component in question meets the approved data/standard and to ensure that the aircraft component is in a satisfactory condition for installation. Additional guidance on the acceptance of components is provided in M.A.402 and 145.A.42.

2.13.Pooled parts at line stations

If applicable, the contract should specify how the subject of pooled parts at line stations should be addressed.

2.14.Scheduled maintenance

For planning scheduled maintenance checks, the support documentation to be given to the maintenance organisation should be specified. This may include but is not limited to:

applicable work package, including job cards;

scheduled component removal list;

modifications to be incorporated.

When the maintenance organisation determines, for any reason, to defer a maintenance task, it has to be formally agreed with the CAMO. If the deferment goes beyond an approved limit, please refer to paragraph 2.17 ‘Deviation from the maintenance schedule’. This should be addressed, where applicable, in the maintenance contract.

2.15.Unscheduled maintenance/defect rectification

The contract should specify to which level the maintenance organisation may rectify a defect without reference to the CAMO. It should describe, as a minimum, the management of approval of repairs and the incorporation of major repairs. The deferment of any defect rectification should be submitted to the CAMO.

2.16.Deferred tasks

See paragraphs 2.14 and 2.15 above, as well as 145.A.50(e) and M.A.801(g). In addition, for aircraft line and base maintenance, the use of the operator’s MEL and the liaison with the CAMO in case of a defect that cannot be rectified at the line station should be addressed.

2.17.Deviation from the maintenance schedule

Deviations from the maintenance schedule have to be managed by the CAMO in accordance with the procedures established in the maintenance programme. The contract should specify the support the maintenance organisation may provide to the operator in order to substantiate the deviation request.

2.18.Maintenance check flight

If any maintenance check flight is required after aircraft maintenance, it should be performed in accordance with the procedures established in the continuing airworthiness management exposition or the operator’s manual.

2.19.Bench test

The contract should specify the acceptability criterion and whether a representative of the CAMO should witness an engine undergoing test.

2.20.Release to service documentation

The release to service has to be performed by the maintenance organisation in accordance with its maintenance organisation procedures. The contract should, however, specify which support forms have to be used (aircraft technical log, maintenance organisation’s release format, etc.) and the documentation that the maintenance organisation should provide to the CAMO upon delivery of the aircraft. This may include but is not limited to:

certificate of release to service,

flight test report,

list of modifications embodied,

list of repairs,

list of ADs accomplished,

maintenance visit report,

test bench report.

2.21.Maintenance record-keeping

The CAMO may subcontract the maintenance organisation to retain some of the maintenance records required by Part-M Subpart C. This means that the CAMO subcontracts under its quality system part of its record-keeping tasks and, therefore, the provisions of M.A.711(a)(3) apply.

2.22.Exchange of information

Each time exchange of information between the CAMO and the maintenance organisation is necessary, the contract should specify what information should be provided and when (i.e. in which case or at what frequency), how, by whom and to whom it has to be transmitted.

2.23.Meetings

The maintenance contract should include the provision for a certain number of meetings to be held between the CAMO and the maintenance organisation.

2.23.1.Contract review

Before the contract is enforced, it is very important that the technical personnel of both parties, that are involved in the fulfilment of the contract, meet in order to be sure that every point leads to a common understanding of the duties of both parties

2.23.2.Work scope planning meeting

Work scope planning meetings may be organised so that the tasks to be performed may be commonly agreed.

2.23.3.Technical meeting

Scheduled meetings may be organised in order to review on a regular basis technical matters such as ADs, SBs, future modifications, major defects found during maintenance check, aircraft and component reliability, etc.

2.23.4.Quality meeting

Quality meetings may be organised in order to examine matters raised by the CAMO’s quality surveillance and to agree upon necessary corrective actions.

2.23.5.Reliability meeting

When a reliability programme exists, the contract should specify the CAMO’s and maintenance organisation’s respective involvement in that programme, including the participation in reliability meetings.

ED Decision 2021/009/R

This appendix includes general instructions for providing training on Fuel Tank Safety issues.

A)Effectivity:

Large aeroplanes as defined in Decision 2003/11/RM of the Executive Director of the Agency (CS-25) and certified after 1 January 1958 with a maximum type certified passenger capacity of 30 or more or a maximum certified payload capacity of 7500 lbs (3402 kg) cargo or more, and

Large aeroplanes as defined in Decision 2003/11/RM of the Executive Director of the Agency (CS-25) which contains CS-25 amendment 1 or later in their certification basis.

B)Affected organisations:

CAMOs involved in the continuing airworthiness management of aeroplanes specified in paragraph A).

Competent authorities responsible for the oversight as per M.B.704 of aeroplanes specified in paragraph A) and for the oversight of the CAMOs specified in this paragraph B).

C)Persons from affected organisations who should receive training:

Phase 1 only:

The quality manager and quality personnel.

Personnel of the competent authorities responsible for the oversight as per M.B.704 of aeroplanes specified in paragraph A) and in the oversight of CAMOs specified in paragraph B).

Phase 1 + Phase 2 + Continuation training:

Personnel of the CAMO involved in the management and review of the continuing airworthiness of aircraft specified in paragraph A);

D)General requirements of the training courses

Phase 1 – Awareness

The training should be carried out before the person starts to work without supervision but not later than 6 months after joining the organisation. The persons who have already attended the Level 1 Familiarisation course in compliance with ED Decision 2007/001/R Appendix XII are already in compliance with Phase 1.

Type: Should be an awareness course with the principal elements of the subject. It may take the form of a training bulletin, or other self-study or informative session. Signature of the reader is required to ensure that the person has passed the training.

Level: It should be a course at the level of familiarisation with the principal elements of the subject.

Objectives:

The trainee should, after the completion of the training:

1.Be familiar with the basic elements of the fuel tank safety issues.

2.Be able to give a simple description of the historical background and the elements requiring a safety consideration, using common words and showing examples of non-conformities.

3.Be able to use typical terms.

Content: The course should include:

a short background showing examples of FTS accidents or incidents,

the description of concept of fuel tank safety and CDCCL,

some examples of manufacturers documents showing CDCCL items,

typical examples of FTS defects,

some examples of TC holders repair data

some examples of maintenance instructions for inspection.

Phase 2 - Detailed training

A flexible period may be allowed by the competent authorities to allow organisations to set the necessary courses and impart the training to the personnel, taking into account the organisation’s training schemes/means/practices. This flexible period should not extend beyond 31 December 2010.

The persons who have already attended the Level 2 Detailed training course in compliance with ED Decision 2007/001/R Appendix XII either from a CAMO or from a Part-147 training organisation are already in compliance with Phase 2 with the exception of continuation training.

Staff should have received Phase 2 training by 31 December 2010 or within 12 months of joining the organization, whichever comes later.

Type: Should be a more in-depth internal or external course. It should not take the form of a training bulletin or other self-study. An examination should be required at the end, which should be in the form of a multi choice question, and the pass mark of the examination should be 75%.

Level: It should be a detailed course on the theoretical and practical elements of the subject.

The training may be made either:

•in appropriate facilities containing examples of components, systems and parts affected by Fuel Tank Safety (FTS) issues. The use of films, pictures and practical examples on FTS is recommended; or

•by attending a distance course (e-learning or computer based training) including a film when such film meets the intent of the objectives and content here below. An e-learning or computer based training should meet the following criteria:

•A continuous evaluation process should ensure the effectiveness of the training and its relevance;

•Some questions at intermediate steps of the training should be proposed to ensure that the trainee is authorized to move to the next step;

•The content and results of examinations should be recorded;

•Access to an instructor in person or at distance should be possible in case support is needed.

A duration of 8 hours for phase 2 is an acceptable compliance.

When the course is provided in a classroom, the instructor should be very familiar with the data in Objectives and Guidelines. To be familiar, an instructor should have attended himself a similar course in a classroom and made additionally some lecture of related subjects.

Objectives:

The attendant should, after the completion of the training:

•have knowledge of the history of events related to fuel tank safety issues and the theoretical and practical elements of the subject, have an overview of the FAA regulations known as SFAR (Special FAR) 88 of the FAA and of JAA Temporary Guidance Leaflet TGL 47, be able to give a detailed description of the concept of fuel tank system ALI (including Critical Design Configuration Control Limitations CDCCL, and using theoretical fundamentals and specific examples;

•have the capacity to combine and apply the separate elements of knowledge in a logical and comprehensive manner;

•have knowledge on how the above items affect the aircraft;

•be able to identify the components or parts or the aircraft subject to FTS from the manufacturer’s documentation,

•be able to plan the action or apply a Service Bulletin and an Airworthiness Directive.

Content: Following the guidelines described in paragraph E).

Continuation training:

The organisation should ensure that the continuation training is performed in each two years period. The syllabus of the training programme referred to in the Training policy of the Continuing Airworthiness Management Exposition (CAME) should contain the additional syllabus for this continuation training.

The continuation training may be combined with the phase 2 training in a classroom or at distance.

The continuing training should be updated when new instructions are issued which are related to the material, tools, documentation and manufacturer’s or competent authority’s directives.

E)Guidelines for preparing the content of Phase 2 courses.

The following guidelines should be taken into consideration when the phase 2 training programme are being established:

a)understanding of the background and the concept of fuel tank safety,

b)how the mechanics can recognise, interpret and handle the improvements in the instructions for continuing airworthiness that have been made or are being made regarding fuel tank systems,

c)awareness of any hazards especially when working on the fuel system, and when the Flammability Reduction System using nitrogen is installed.

Paragraphs a), b) and c) above should be introduced in the training programme addressing the following issues:

i)The theoretical background behind the risk of fuel tank safety: the explosions of mixtures of fuel and air, the behaviour of those mixtures in an aviation environment, the effects of temperature and pressure, energy needed for ignition, etc., the ‘fire triangle’, - Explain 2 concepts to prevent explosions:

(1)ignition source prevention and

(2)flammability reduction,

ii)The major accidents related to fuel tank systems, the accident investigations and their conclusions,

iii)SFAR 88 of the FAA and JAA Interim Policy INT POL 25/12: ignition prevention program initiatives and goals, to identify unsafe conditions and to correct them, to systematically improve fuel tank maintenance),

iv)Explain briefly the concepts that are being used: the results of SFAR 88 of the FAA and JAA INT/POL 25/12: modifications, airworthiness limitations items and CDCCL,

v)Where relevant information can be found and how to use and interpret this information in the applicable maintenance data as defined in M.A.401(b),

vi)Fuel Tank Safety during maintenance: fuel tank entry and exit procedures, clean working environment, what is meant by configuration control, wire separation, bonding of components etc.,

vii)Flammability reduction systems when installed: reason for their presence, their effects, the hazards of a Flammability Reduction System (FRS) using nitrogen for maintenance, safety precautions in maintenance/working with an FRS,

viii)Recording maintenance actions, recording measures and results of inspections.

The training should include a representative number of examples of defects and the associated repairs as required by the TC/STC holders maintenance data.

F)Approval of training

For CAMOs the approval of the initial and continuation training programme and the content of the examination can be achieved by the change of the CAME exposition. The modification of the CAME should be approved as required by M.A.704(b). The necessary changes to the CAME to meet the content of this decision should be made and implemented at the time requested by the competent authority.

ED Decision 2020/002/R

The following text provides relevant information for conducting organisational reviews in accordance with M.A.712 for the particular case of a CAMO working on aircraft subject to Part-M.

Organisational reviews may replace a full quality system in accordance with the provisions of M.A.712(f) and AMC M.A.712(f) and as described in the continuing airworthiness management exposition (CAME)

Depending on the complexity of the small organisation (number and type of aircraft, number of different fleets, privilege to perform airworthiness reviews, etc.), the organisational review system may vary from a system using the principles and practices of a quality system (except for the requirement of independence) to a simplified system adapted to the low complexity of the organisation and the aircraft managed.

As a core minimum, the organisational review system should have the following features, which should be described in the CAME:

a.Identification of the person responsible for the organisational review programme:

By default, this person should be the accountable manager, unless he delegates this responsibility to (one of) the M.A.706(c) person(s).

b.Identification and qualification criteria for the person(s) responsible for performing the organisational reviews:

These persons should have a thorough knowledge of the regulations and of the continuing airworthiness management organisation (CAMO) procedures. They should also have knowledge of audits, acquired through training or through experience (preferably as an auditor, but also possibly because they actively participated in several audits conducted by the competent authority).

c.Elaboration of the organisational review programme:

Checklist(s) covering all items necessary to be satisfied that the organisation delivers a safe product and complies with the regulation. All procedures described in the CAME should be addressed.

A schedule for the accomplishment of the checklist items. Each item should be checked at least every 12 months. The organisation may choose to conduct one full review annually or to conduct several partial reviews.

d.Performance of organisational reviews:

Each checklist item should be answered using an appropriate combination of:

review of records, documentation, etc.

sample check of aircraft under contract.

interview of personnel involved.

review of discrepancies and difficulty internal reports (e.g., notified difficulties in using current procedures and tools, systematic deviations from procedures, etc.).

review of complaints filed by customers.

e.Management of findings and occurrence reports:

All findings should be recorded and notified to the affected persons.

All level 1 findings, in the sense of M.A.716(a), should be immediately notified to the competent authority and all necessary actions on aircraft in service should be immediately taken.

All occurrence reports should be reviewed with the aim for continuous improvement of the system by identifying possible corrective and preventive actions. This should be done in order to find prior indicators (e.g., notified difficulties in using current procedures and tools, systematic deviations from procedures, unsafe behaviours, etc.), and dismissed alerts that, had they been recognised and appropriately managed before the event, could have resulted in the undesired event being prevented.

Corrective and preventive actions should be approved by the person responsible for the organisational review programme and implemented within a specified time frame.

Once the person responsible for the organisational review programme is satisfied that the corrective action is effective, closure of the finding should be recorded along with a summary of the corrective action.

The accountable manager should be notified of all significant findings and, on a regular basis, of the global results of the organisational review programme.

Following is a typical example of a simplified organisational review checklist, to be adapted as necessary to cover the CAME procedures:

1 – Scope of work

All aircraft under contract are covered in the Form 14.

The scope of work in the CAME does not disagree with the Form 14.

No work has been performed outside the scope of the Form 14 and the CAME.

Is it justified to retain in the approved scope of work aircraft types for which the organisation has no longer aircraft under contract?

2 – Airworthiness situation of the fleet

Does the continuing airworthiness status (AD, maintenance programme, life limited components, deferred maintenance, ARC validity) show any expired items? If so, are the aircraft grounded?

3 – Aircraft maintenance programme

Check that all revisions to the TC/STC holders Instructions for Continuing Airworthiness, since the last review, have been (or are planned to be) incorporated in the maintenance programme, unless otherwise approved by the Competent Authority.

Has the maintenance programme been revised to take into account all modifications or repairs impacting the maintenance programme?

Have all maintenance programme amendments been approved at the right level (competent authority or indirect approval)?

Does the status of compliance with the maintenance programme reflect the latest approved maintenance programme?

Has the use of maintenance programme deviations and tolerances been properly managed and approved?

4 – Airworthiness Directives (and other mandatory measures issued by the competent authority)

Have all ADs issued since the last review been incorporated into the AD status?

Does the AD status correctly reflect the AD content: applicability, compliance date, periodicity…? (sample check on ADs)

5 – Modifications/repairs

Are all modifications/repairs listed in the corresponding status approved in accordance with M.A.304? (sample check on modifications/repairs)

Have all the modifications/repairs which have been installed since the last review been incorporated in the corresponding status? (sample check from the aircraft/component logbooks)

6 – Relations with the owners/operators

Has a contract (in accordance with Appendix I to Part-M) been signed with each external owner/operator, covering all the aircraft whose airworthiness is managed by the CAMO?

Have the owners/operators under contract fulfilled their obligations identified in the contract? As appropriate:

•Are the pre-flight checks correctly performed? (interview of pilots)

•Are the technical log or equivalent correctly used (record of flight hours/cycles, defects reported by the pilot, identification of what maintenance is next due etc.)?

•Did flights occur with overdue maintenance or with defects not properly rectified or deferred? (sample check from the aircraft records)

•Has maintenance been performed without notifying the CAMO (sample check from the aircraft records, interview of the owner/operator)?

7 – Personnel

Check that the current accountable manager and other nominated persons are correctly identified in the approved CAME.

If the number of personnel has decreased or if the activity has increased, check that the organisation still has sufficient staff.

Check that the qualification of all new personnel (or personnel with new functions) has been appropriately assessed.

Check that the staff has been trained, as necessary, to cover changes in:

•regulations,

•competent authority publications,

•the CAME and associated procedures,

•the approved scope of work,

•maintenance data (significant ADs, SBs, ICA amendments, etc.).

8 – Maintenance contracted

Sample check of maintenance records:

•Existence and adequacy of the work order,

•Data received from the maintenance organisation:

•Valid CRS including any deferred maintenance

•List of removed and installed equipment and copy of the associated Form 1 or equivalent.

Obtain a copy of the current approval certificate (Form 3) of the maintenance organisations contracted.

9 – Technical records and record-keeping

Have the certificates (Form 1 and Conformity certificates) been properly collected and recorded?

Perform a sample check of technical records to ensure completeness and storage during the appropriate periods.

Is storage of computerised data properly ensured?

10 – Occurrence reporting procedures

Check that reporting is properly performed,

Actions taken and recorded.

11 – Airworthiness review