Under the present rules, how can a maintenance organisation extend the use of the privileges specified in 145.A.75(c) of line maintenance performed away from an approved location?
Answer
1. Purpose of the document
Considering the impact of the COVID-19 crisis on the aviation sector – a large number of aircraft grounded at airports/ locations where there is no maintenance organisation which can perform the required maintenance/ preservation tasks, to name but a few – the Agency was requested to provide to competent authorities (CAs) with additional guidance material to facilitate a simpler process of approving changes to the applicable organisation’s procedures. This document is therefore intended to guide CAs in keeping continuing compliance with the applicable requirements and ensure, as much as possible, the continuation of maintenance organisation activities.
The guidance provided in this document is primarily intended for Part-145 organisations, but can be used also in case of Part-M, Subpart F and Part-CAO organisations, if needed.
2. Description of the issue
In accordance with 145.B.35 and 145.B.40 of Regulation (EU) 1321/2014, the CA may consider to approve a concession to allow deviating from the Maintenance Organisation Exposition (MOE) procedures for maintenance performed away from an approved location, as per 145.A.75(c) and permit the performance of line maintenance in a non-approved location for a period up to 3 months (90 days).
The maintenance organisation may be allowed to perform line maintenance at such a location without having the obligation to get the approval of a line station in accordance with 145.A.85 i.e. without the need to declare the location in the MOE as required by 145.A.75(d).
The concession will be controlled by the maintenance organisation in accordance with MOE Ch. 3.10.
3. Considerations for the competent authority (CA)
When deciding on approving such a concession (requested by the maintenance organisation), the CA should take into consideration its duration period and the conditions for applying the respective change of procedure, based on at least the following aspects:
- previous performance of the organisation; and
- confidence of the competent authority in the ability of the internal quality system of the organisation to ensure safe operations.
After the initial period of the approved concession, the competent authority may reassess, following the same process as described above, the situation and may approve an additional extension of the initial period with another maximum 3 months (90 days) together with specifying the related conditions, as necessary.