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Aircrew
Medical
Flight Simulation Training Devices (FSTDs)
General
Continuing Airworthiness
Air Operations
Level of Involvement (LOI)
Airspace Usage requirements
Third Country Operators (TCO)
Initial Airworthiness
- Instructions for Continued Airworthiness (ICA)
Additional Airworthiness specifications
Basic Regulation
ATCO Licensing
Air Traffic Management (ATM) / Air Navigation Services (ANS)
Air Traffic Management / Air Navigation Services (ATM/ANS) ground equipment
Aerodromes (ADR)
- Aerodromes
- Rescue and Firefighting
Drones (UAS)

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Aircrew

Operational Suitability Data (OSD) for flight crew (FC)

What is the content and purpose of the EASA type rating and licence endorsement lists?

The data approved in the OSD FC are linked to the minimum training syllabus for a pilot type rating. An evaluation of differences (e.g. for aircraft modifications or between variants) identifies minimum training levels and associated training devices, if required.

With regard to the acquisition of knowledge through theoretical training, some elements may be validated as Level A and can be adequately addressed through self-instruction, whereas other elements may require aided instruction and are identified as Level B. Training organisations may find it more practical to combine Level A and Level B elements into one module of the higher level (such as computer-based training or instructor-led sessions).

With regard to the acquisition of skills through practical training, the OSD FC minimum syllabus identifies elements requiring Level C, D or E practical training and these elements are usually associated in the OSD FC document with specified training devices.

In principle, the devices described in the OSD FC document and the devices used in pilot training should be of the same training level. The use of a more complex device requires additional considerations, regarding the capabilities and characteristics of the device and the impact this may have on the training objective(s).

As an example, the OSD FC may refer to an FMS desktop trainer for Level C training. FMS training in an FTD, an FFS (without motion or vision) or in the aircraft (static, on power) may provide the same training objectives. However, the more complex training environment introduces elements which may affect the focus of the training, the time required, or other factors and these should be taken into consideration.

The same principles apply for the substitution of an FTD. To replicate the characteristics of an FTD Level I with an FTD Level II, to replicate an FTD Level I with an FFS (without motion or vision), or to replicate an FTD Level II with an FFS (without motion or vision) require different considerations to preserve achievement of the training objective.

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Licensing

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Medical fitness

My cabin crew qualification document was issued in a country that is not a member of the European Union and is not an EASA Member State either. Is my cabin crew qualification document recognised in the European Union?

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Fire and smoke training

What are the requirements for cabin crew fire/smoke training?

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What is the content of fire and smoke training during the Initial training ?

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Language proficiency

Is there any requirement on cabin crew member(s) communication with passengers in a certain language?

Reference: Regulation (EU) No 965/2012 Air Operations, Annex III (Part-ORO) and Annex IV (Part-CAT) is available on EASA website.

There is no EU (or ICAO requirement) that cabin crew members must speak English. It is a general practice that cabin crew members do speak English to facilitate the communication in the aviation industry. The operator defines what languages its cabin crew members must be able to speak and at what level.

Regulation (EU) No 965/2012 specifies the following two requirements:

The operator shall ensure that all personnel are able to understand the language in which those parts of the Operations Manual, which pertain to their duties and responsibilities, are written (ORO.MLR.100(k)), and
The operator shall ensure that all crew members can communicate with each other in a common language (CAT.GEN.MPA.120).
There is no EU (or ICAO) requirement for a specific language regarding cabin crew communication with passengers. It must be noted that it is difficult, if not impossible, to mandate the ‘required’ languages to be used on board with regard to communication with passengers, as this differs on daily basis from a flight to flight. For example, a German airline has a flight departing from Frankfurt to Madrid and it is assumed that the cabin crew members speak German since they work for a German operator. In addition, they may speak English if the operator selected this language as a criterion. The passenger profile may, however, be such that these languages are not ‘desired’ on this flight as passengers do not necessarily speak or understand any of the two languages (passengers may be e.g. Russian, Chinese, Iranian, Indian, Pakistani, Polish, Finnish, Croatian, Hungarian, Bulgarian, Czech, Slovak, etc., or there is a large group of e.g. Japanese tourists).

Regulation (EU) No 965/2012 mandates the operator to ensure that briefings and demonstrations related to safety are provided to passengers in a form that facilitates the application of the procedures applicable in case of an emergency and that passengers are provided with a safety briefing card on which picture type-instructions indicate the operation of emergency equipment and exits likely to be used by passengers. It is therefore the operator’s responsibility to choose the languages to be used on its flights, which may vary depending on the destination or a known passenger profile. It is also a practice of some operators to employ ‘language speakers’, i.e. cabin crew members speaking certain languages, who mainly operate their language-desired route(s).

Can a cabin crew training organisation (CCTO) provide Aircraft type specific training and operator conversion training?

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Reduction of cabin crew during ground operations

Do the evacuation procedures with a reduced number of required cabin crew during ground operations or in unforeseen circumstances require prior endorsement?

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Minimum required cabin crew

Determination of the minimum required number of cabin crew on an aircraft

NOTE: The purpose of this FAQ is to explain how the operator and the Competent Authority (National Aviation Authority) conclude the minimum number of cabin crew required on the operator’s aircraft. This FAQ does not provide specific numbers for aircraft types or individual aircraft. The minimum number of cabin crew may vary on each aircraft, depending on the certification history of that aircraft. To learn the minimum number of cabin crew on your aircraft, please, consult your Competent Authority. To have a better view and understanding of the explanation below, this FAQ should be read together with the rule ORO.CC.100 (Regulation (EU) No 965/2012 on air operations).
Minimum number of cabin crew is established during the certification process of the aircraft and this number must be clearly written in the certification documentation (reference: EASA Certification Memorandum CM-CS-008, issued on 03 July 2017). The ‘certification documentation’ is the Type Certificate Data Sheet (TCDS) or the Supplemental Type Certificate (STC).

Therefore, in order to establish the minimum number of cabin crew on the operator’s aircraft, as specified in ORO.CC.100(b)(1) of Regulation (EU) No 965/2012, the operator/National Aviation Authority must check the aircraft certification documentation and apply the number written in the certification documentation.

However, historically, not all aircraft had the number of minimum cabin crew written in the certification documentation, or even established during the certification process. In this case, the operator may use the calculation method specified in ORO.CC.100(b)(2) of Regulation (EU) No 965/2012.

In summary:
Certification documentation of the operator’s aircraft issued:

Before 3rd July 2017: if the certification documentation does not include the number of minimum cabin crew or the number has not been established for the aircraft, you may apply the calculation method specified in ORO.CC.100(b)(2)).
After 3rd July 2017: you must apply the number of minimum cabin crew specified in the certification documentation in accordance with the rule ORO.CC.100(b)(1).

Background information:
The development stage of Regulation (EU) No 965/2012 (‘AIR OPS’) initially did not include the paragraph (b)(2) in ORO.CC.100, i.e. the ‘1 per 50’ calculation. This inclusion was done last minute and it resulted in the overall lack of clarity of ORO.CC.100(b). To help with the implementation, EASA published Safety Information Bulletin (SIB) 2014-29, which provided detailed information on how to comply with ORO.CC.100. The SIB was supported by the EU Members States, however resulted in a strong opposition by EU operators. As a result, discussions were held in 2015 between EASA and IATA/IACA on the application of ORO.CC.100(b), i.e. how to establish the minimum required number of cabin crew. As an outcome of these discussions, on 7th December 2015 EASA communicated to the stakeholders the ‘EASA conclusions following the consultation on the proposed Certification Memo and Safety Information Bulletin on minimum cabin crew for twin‐aisle aeroplanes’.

On 3rd July 2017, EASA published the above-mentioned Certification Memorandum EASA-CM-CS-008. This document clarifies to aircraft manufacturers and design organisations that the number of cabin crew assumed in their evacuation certification activity must be clearly stated in their documentation. Following the publication of this Certification Memorandum, the TCDSs have been amended to include the minimum number of cabin crew. Some aircraft manufacturers have amended their TCDSs even before the publication of this Certification Memorandum.

There may be cases where the minimum number of cabin crew for the operator’s aircraft will be different (e.g. lower) than the number written in the TCDS. Such a change must be approved by EASA and such an aircraft will hold a Supplemental Type Certificate. STC means that it was demonstrated that the aircraft cabin configuration used by the operator is compliant with the applicable certification specifications with a lower number of cabin crew members than the number specified in the TCDS. If the operator’s aircraft holds a STC, the number of minimum cabin crew written in the STC will be applicable to that aircraft.

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Working for multiple operators

Flight Simulation Training Devices (FSTDs)

CS- FSTD(A) Issue 2 - UPRT Compliance of current qualified FSTD

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Where can I find more information about Flight Simulation Training Devices (FSTDs)?

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General

Where can I find guidance on the use of ‘shall’, ‘must’, ‘should’ and ‘may’ in the Agency’s rulemaking publications and generally in EU legislation?

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What is the difference between European Community (EC) and European Union (EU) in the regulation reference?

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Why has the numbering of the EU regulations changed as of 2015?

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What is the definition of an IR, AMC and CS and GM and what differences can be proposed?

Implementing Rules (IR) are binding in their entirety and used to specify a high and uniform level of safety and uniform conformity and compliance. The IRs are adopted by the European Commission in the form of Regulations.

Acceptable Means of Compliance (AMC) are non-binding. The AMC serves as a means by which the requirements contained in the Basic Regulation, and the IR, can be met. However, applicants may decide to show compliance with the requirements using other means. Both NAAs and organisations may propose alternative means of compliance. ‘Alternative Means of Compliance’ are those that propose an alternative to an existing AMC. Those Alternative Means of Compliance proposals must be accompanied by evidence of their ability to meet the intent of the IR. Use of an existing AMC gives the user the benefit of compliance with the IR.

Certification Specifications (CS) are non-binding technical standards adopted by the EASA to meet the essential requirements of the Basic Regulation. CSs are used to establish the certification basis (CB) as described below. Should an aerodrome operator not meet the recommendation of the CS, they may propose an Equivalent Level of Safety (ELOS) that demonstrates how they meet the intent of the CS. As part of an agreed CB, the CS become binding on an individual basis to the applicant.

Special Conditions (SC) are non-binding special detailed technical specifications determined by the NAA for an aerodrome if the certification specifications established by the EASA are not adequate or are inappropriate to ensure conformity of the aerodrome with the essential requirements of Annex Va to the Basic Regulation. Such inadequacy or inappropriateness may be due to:

the design features of the aerodrome; or
where experience in the operation of that or other aerodromes, having similar design features, has shown that safety may be compromised.

In case the answer you were looking for in this FAQ section is not available, you are invited to contact first your competent authority (here for EASA member states). For further assistance, you might submit your enquiry, together with the description of your authority’s position, here.

Easy Access Rules for Continuing Airworthiness (Regulation (EU) No 1321/2014), covering covering Part-M, Part-145, Part-66, Part-147 and Part-T.

COVID-19 - Continuing Airworthiness

What is the flexibility allowed to the person or organisation responsible for the aircraft continuing airworthiness when it comes to the planning of Aircraft Maintenance Programme (AMP) scheduled maintenance tasks with intervals expressed in calendar time?

1. Purpose of the document

The Agency was requested by the industry for additional guidance on the application of the airworthiness rules in respect to certain specific issues particularly affected by the current COVID-19 crisis. One of those topics concerns the obligations of the person or organisation responsible for continuing airworthiness of aircraft when it comes to the accomplishment of Aircraft Maintenance Programme tasks with intervals expressed in calendar times. Accordingly, the Agency prepared this additional, temporary, guidance, which complements the existing AMC/GM to Commission Regulation (EU) No 1321/2014.

The guidance provided in this document is primarily intended for ‘Part-M’ aircraft, but can be used also as regards ‘Part-ML’ aircraft, except that in case of ‘Part-ML’ aircraft, the competent authority does not need to be involved if an AMP task is to be postponed, as this is done under the responsibility of the aircraft owner or the organisation responsible for the aircraft continuing airworthiness. This person or organisation may also decide, if necessary to revise the AMP, which will not involve the competent authority.

2. Description of the issue

During the COVID-19 crisis, a large number of aircraft is being parked / stored at different and partially remote locations. This guidance document was prepared based on an assumption that these aircraft have been subject to parking/storage procedures defined by the Type Certificate (TC) Holder (those parking and storage procedures are usually contained in a chapter of the Aircraft Maintenance Manual (AMM e.g. Chapter 10). If the existing AMM does not contain parking/storage procedures, the TC Holder should be contacted.

Note: It is not necessary to revise the AMP to include the parking/storage tasks to be followed.

During the COVID-19 crisis, the parked/stored aircraft are not operated and consequently the AMP scheduled maintenance tasks based on ‘Flight hours’ and ‘Flight cycles’ are not impacted. On the other hand the AMP scheduled maintenance tasks based on intervals (and threshold, if applicable) expressed in calendar times need to be considered. Indeed, some of the calendar time based scheduled maintenance tasks will become due during parking/storage period.

In the normal practice, following the principles of AMC M.A.301(c) and point 4 of Appendix I to AMC M.A.302 and AMC M.B.301(b), if a scheduled maintenance task cannot be performed within the interval approved in the AMP, its postponement may be allowed in accordance with pre-defined ‘permitted variation’ agreed with the CA in the AMP.

3. Considerations in the frame of COVID-19 crisis

3.1 Postponement until the end of parking/storage period
In the current situation, it may not be always feasible, to perform the calendar scheduled maintenance tasks of the AMP in due time, or within the permitted variation specified in the AMP.
In such cases, it is acceptable for EASA to plan the accomplishment of these tasks (even if they have become due multiple times during the parking/storage period) at the next suitable opportunity (e.g. next weekly check of storage/parking procedure), or at the end of the storage/parking period, but in any case before the next flight, as part of the work package necessary for the de-preserving/de-storage of the aircraft.

Note: Certain AMP scheduled maintenance tasks may be assessed as unnecessary because they are covered by equivalent tasks in the parking/storage procedures put in place.

3.2 Postponement beyond return to service
If exceptionally, a calendar task needs to be postponed until after the return to service and beyond the AMP permitted variation, the aircraft owner or CAMO/CAO should receive advice from the TCH or the Design Approval holder (DAH) on such postponement and on the subsequent due date after the accomplishment.

The applicant should then submit such postponement, together with the proposed technical justification, including if appropriate, a risk assessment, for approval by the CA.
The CA should consider the following conditions, mitigating actions or any other elements which the CA deems necessary, when allowing a postponement of a due calendar task after return to service:

An approved maintenance organisation has applied the appropriate parking/storage procedures during the full period.
The owner/CAMO/CAO has monitored what AMP tasks are due (M.A.708(b)(4), CAMO.A.315(b)(5) and CAO.A.075(b)(7)).
This does not apply to mandatory continuing airworthiness instructions (MCAI) such as AD or ALS tasks.
The environmental conditions where the aircraft was parked/stored have been taken into consideration. Certain calendar tasks may be more relevant to a particular storage environment, e.g. wet, salty conditions propagate corrosion.

2. Description of the issue

In accordance with:

For Part 21, Subpart F: points 21.A.125A and 21.A.126(a)(3)/GM No 2 to 21.A.126(a)(3);
For Part 21, Subpart G: points 21.A.139(b)1.(vii), 21.A.143(a)(11) and 21.A.145(a)/GM 21.A.145(a); and
For Part-M, Subpart F; Part-CAO and Part-145: as applicable, points M.A.604(a)7, M.A.608(b), CAO.A.050(b), CAO.A.025(a)(10), 145.A.40(b), 145.A.70(a)12., M.A.402(d) and ML.402(b)(4),

the production or maintenance organisation shall ensure, by complying with adequate procedures included in its exposition or manual, that all tools and equipment, as appropriate, are controlled and calibrated/periodically checked according to an officially recognised standard at a frequency to ensure serviceability and accuracy.

When such a procedure includes a recurrent calibration/periodical check of tools or equipment, it is possible that, due to the COVID-19 crisis, the procedure cannot be complied with because a recurring calibration/periodical check cannot be carried out before the specified due date. In such a case, a temporary change (direct or indirect approved or concessions) to the procedure may be acceptable in order to allow continuation of the activities in compliance with the rules.

In accordance with:

For Part 21, Subpart F: points 21.A.125A and 21.B.140;
For Part 21, Subpart G: points 21.A.143, 21.A.147 and 21.B.240;
For Part-M, Subpart F: points M.A.604, M.A.617 and M.B.606;
For Part-CAO: points CAO.A.025, CAO.A.105 and CAO.B.065; and
For Part-145: points 145.A70, 145.A.85 and 145.B.35,

the competent authority may approve a temporary change to the applicable organisation’s procedure to allow an extension of the period at the end of which the calibration/periodical check of the tool or equipment is due.

3. Considerations for the competent authority (CA) and the organisations

The decision of the competent authority on the approval of such a temporary change should be taken based on a risk analysis performed by the organisation. The risk analysis shall consider the previous performance and reliability of the tool or equipment, previous calibration and periodical checks results and possible additional mitigating measures (like using tools from other organisations for critical applications).

Few considerations for the risk analysis may be, but are not limited to the following:

when the normal calibration/check period is ≤ 12 months the extension of the calibration and/or periodical check can be up to a maximum of 10 % of the normal calibration/check;
when the calibration/check period is > 12 months the extension of the calibration can be 10 % of the normal calibration/check period up to a maximum of 3 months;
the risk associated to the use of the tool or equipment for the specific task in relation to ensuring conformity with the approved data or continuing airworthiness of the aircraft or components is not determined critical;
the tool or equipment is inspected before use and no damage or corrosion is identified;
the tool or equipment was recently used (e.g. within the 3 months preceding the calibration or periodical check due date);
no deficiency with the use of this tool or equipment has been reported since the last calibration or periodical check;
the last two calibration results or last periodical checks are not showing any possible issues (e.g.: drift in the value, value very close to the acceptable limit, etc.) that can endanger the result of the activity performed.

If the risk associated to the use of the tool or equipment for the specific task is identified as critical, the organisation shall receive the tool or equipment manufacturer extension acceptance, and shall take additional measures to verify and ensure the correct production / maintenance results, such as:
verification of the tool or equipment serviceability by comparison with another tool/equipment duly calibrated/periodically checked, and/or
verification of the measurement/test/job-result by other acceptable means.

The tools or equipment with extended calibration or maintenance interval, should be recorded in a dedicated form, allowing tracking the tasks performed. If the tool / equipment fails during next regular calibration / inspection, the completed tasks may require to be verified / performed again.

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Under the present rules, can a maintenance organisation continue to keep a supplier on the approved list even if full compliance with its evaluation of suppliers’ procedure cannot be ensured?

1. Purpose of the document

Considering the impact of the COVID-19 crisis on the aviation sector - the reduced personnel in the maintenance organisations, or late feedback/reply from their suppliers which may affect compliance with their suppliers’ evaluation procedures - the Agency was requested to provide to competent authorities (CA´s) with additional guidance material to facilitate a simpler process of approving changes to the applicable organisation’s procedures, in order to ensure as much as possible the continuation of maintenance organisation activities in compliance with the applicable requirements.
This document is therefore intended to guide CA´s in keeping continuing compliance with the applicable requirements and ensure, as much as possible, the continuation of maintenance organisation activities.

2. Description of the issue

In accordance with 145.A.70(a)(12), 145.A.42(b)(i), M.A.604(a)(7), CAO.A.025(a)(10), M.A.501(b) and ML.A.501(a)(i) of Regulation (EU) 1321/2014, as applicable, the approved organisation carrying out maintenance on products or components have to ensure, by complying with adequate procedures included in the exposition or manual (MOE chapter 2.1, MOM chapter 2.8 or CAE chapter C.3), that the necessary components, standard parts and/or material are supplied in satisfactory conditions. When such a procedure includes a recurrent evaluation of a supplier’s quality system based on a questionnaire which is periodically sent by the maintenance organisation to the supplier, it is possible that, due to the COVID-19 crisis, the procedure cannot be complied with. In such a case, a temporary change to the procedure (including concessions), in accordance with 145.A.70(b), M.A.604(b) and CAO.A.105(a) 5, as applicable, may be acceptable in order to allow continuation of the activities in compliance with the rules.

3. Considerations for the competent authority (CA)

In accordance with 145.B.35, 145.B.40, M.B.606(c) or CAO.B.065 of said Regulation, the competent authority may approve (direct or indirect) a temporary change to the applicable organisation’s procedure to allow an extension of the period for evaluation of the suppliers’ performance (when based on a questionnaire sent to supplier) up to 3 months in order to maintain the respective suppliers on the approved list of suppliers, based on a risk assessment which considers at least the following elements:

confidence in the quality system / organisational review of the maintenance organisation; and
analysis performed by the maintenance organisation to support the extension, taking into account the criticality of the supplied articles, the results of the previous evaluation of the respective supplier and the supplier’s performance.

After the agreed extension period the situation may be reassessed and an additional extension of the initial period up to a maximum of 3 additional months may be envisaged by the CA, following the same process as the one described above (change of the organisation’s applicable procedure).

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Is there any possibility to temporary extend the validity of NDT personnel certification due to coronavirus (COVID-19) crisis?

According to the industry standard EN4179, recognised by the EASA via AMC 145.A.30(f) and AMC M.A.606(f) to be used for qualification of NDT personnel, the NDT personnel Level 1, 2 and 3 shall be recertified every 5 years. No flexibility is given by EN4179 to deviate from the specific requirements of EN4179, Chapter 8 related to the recertification of NDT personnel process.

Due to the extraordinary worldwide coronavirus crisis, the recertification requirements might not be fulfilled (examinations). Other impacted processes can be “annual maintenance” and “vision examination” which invalidate the certification if not performed on time.

In these circumstances, the Agency recommends the organisation to agree with the Competent Authority a deviation from the organisation’s procedure (e.g. in case of Part-145 to use the normal concession process - deviation from an approved exposition (MOE) for a limited period of time) in case of a need to temporary extend (without fulfilling the normal requirements) the validity of NDT personnel certification, annual maintenance and/or vision examination. The organisation should contact their Competent Authority surveyor and agree on mitigating measures depending on the extent of the concession needed (e.g. EN4179 para. 8.3.2, second and fourth bullet points could offer grounds for mitigation measures).

For standardisation reasons, it is recommended that each National Aerospace NDT Board (NANDTB) together with the corresponding Competent Authority establishes the general scenario to be followed by the organisations (e.g. by an information notice on the NANDTB website or by e-mail etc.). This will be further adapted to the specific case (e.g. in the case of a Part-145 organisation with D1 rating additional mitigation measure could be taken for the NDT personnel who is also certifying staff).

Same principles can be applied by Part-21 Subpart G and F organisations having the NDT personnel qualified/certified i.a.w. EN 4179 when applying the GM 21.A.145(a) or GM No 2 to 21.A.126(a)(3).

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Interpretation and policy papers

Continuing airworthiness - General

Concerning the approval of the continuing airworthiness organisations, what is the sharing of responsibilities between EASA and the national competent authorities of the EASA Member States? How to get the lists of the approved continuing airworthiness organisations?

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Where can I find the continuing airworthiness requirements for third-country registered aircraft used by EU operator/owner?

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How to use information and communication technologies for performing remote audits on to DOA, LoA/POA, AMO, CAMO, CAO and AMTO holders*?

Objective of this document:
This document provides technical guidance on the use of remote information and communication technology (ICT) to support:

the competent authorities when performing the oversight of regulated organisations and
the industry when conducting internal audits / monitoring compliance of the organisation with the relevant requirement and when performing evaluation of suppliers and subcontractors.

It is the responsibility of the competent authority to assess whether the use of remote ICT constitutes a suitable alternative to the physical presence of the auditor on-site in accordance with the applicable requirements.

In the context of this document, “remote audit” is understood as an audit performed with the use of any real-time video and audio communication tools in replacement of the physical presence of the auditor on-site. Specificities of each type of approval / letter of agreement need to be considered in addition to the below general overview when applying the “remote audit” concept.

1. Conduct of remote audit by a Competent Authority

Competent authorities who decide to use remote audit should describe the remote audit process in their documented procedures and should consider at least the following elements:

Methodology for the use of ICT is sufficiently flexible and non-prescriptive in nature to optimise the conventional audit process.
Adequate controls are defined and in place to avoid abuses that could compromise the integrity of the audit process.
Measures to ensure that security and confidentiality are maintained throughout the audit activities (data protection and intellectual property of the organisations also need to be safeguarded).

Examples of use of ICT during audits may include but are not limited to:

meetings, by means of teleconference facilities, including audio, video and data sharing;
assessment of documents and records by means of remote access, in real-time;
recording, in real-time during the process, of evidence to document the results of the audit (non-/conformities) by means of exchange of emails or documents, instant pictures, video or/and audio recordings;
visual (livestream video) and audio access to facilities, stores, equipment, tools, processes, operations, etc.

An agreement between the competent authority and the organisation should be established when planning a remote audit which should include:

determining the platform for hosting the audit (e.g. Go-To-Meeting, WebEx, Microsoft Lync, Microsoft TEAMS, etc.);
granting security and/or profile access to the auditor;
testing platform compatibility between the competent authority and organisation prior to the audit;
considering the use of web-cams, cameras, drones, etc. when physical evaluation of an event (product, part, process, etc.) is desired or necessary;
establishing an audit plan which will identify how ICT will be used and the extent of its use for the audit purposes to optimise its effectiveness and efficiency while maintaining the integrity of the audit process;
if necessary, time zone acknowledgement and management to coordinate reasonable and mutually agreeable convening times;
a written statement of the organisation that they ensure full cooperation and provision of the actual and valid data as requested, including ensuring any supplier or subcontractor cooperation, if needed; and
data protection aspects.

The following elements of the equipment and setup should be considered:

the suitability of video resolution, fidelity, and field of view for the verification being conducted;
the need for multiple cameras, imaging systems, or microphones and whether the person performing the verification can switch between them, or direct them to be switched and has the possibility to stop the process, ask a question, move equipment, etc.;
the controllability of viewing direction, zoom, and lighting;
the appropriateness of audio fidelity for the evaluation being conducted; and
real-time and uninterrupted communication between the person(s) participating to the remote audit from both locations.

When using ICT, the competent authority and other involved persons (e.g. drone pilots, technical experts) should have the competency and ability to understand and utilize the ICT tools employed to achieve the desired results of audit(s)/assessment(s). The competent authority should also be aware of the risks and opportunities of the ICT used and the impacts that they may have on the validity and objectivity of the information gathered.

Audit reports and related records should indicate the extent to which ICT has been used in carrying out remote audit and the effectiveness of ICT in achieving the audit objectives, including any item that was not able to be completely reviewed.

2. Internal Audits performed by approved organisation and evaluation of its suppliers and subcontractors

The considerations described in paragraph 1 may also be applied by approved organisations when conducting internal audits / monitoring compliance of the organisation with the relevant requirements and when performing evaluation of suppliers and subcontractors. The application of “remote audit” concept should be described in a documented procedure accepted / approved by the Competent Authority.

* DOA: Design Organisation Approval; LoA/POA: Letters of Approval/Production Organisation Approval; AMO: Maintenance Organisation Approval; CAMO: Continuing Airworthiness Management Organisations Approval; CAO: Combined Airworthiness Organisation Approval; and AMTO: Maintenance Training Organisation Approval

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Can a Pilot-Owner or Flight Crew accomplish an inspection required by an AD?

The provisions for a Pilot-Owner or Flight Crew to accomplish AD actions are to be found in Commission Regulation (EU) No 1321/2014 on the continuing airworthiness of aircraft and aeronautical products, parts and appliances, and on the approval of organisations and personnel involved in these tasks, Annex I (Part-M), Annex II (Part-145), Annex Vb (Part-ML) & Annex Vd (Part-CAO).

For AD tasks carried out by Flight Crew:

IF INDICATED IN THE AD (*- see Note), THE FOLLOWING APPLIES:
145.A.30(j)3 or M.A.606(h)1 Personnel requirements, or CAO.A.040(c)(1) Certifying staff.

For a repetitive pre-flight task, where the AD specifically states that the flight crew may carry out such task, the organisation (Part-145, Part-M Subpart F or Part-CAO maintenance organisation) may issue a limited certifying staff authorisation to the pilot-in command/aircraft commander on the basis of the flight crew licence held, provided that the organisation ensures that sufficient practical training has been carried out to ensure that such person can accomplish the AD task to the required standard. A repetitive pre-flight task in an AD does not mean that the task needs to be certified prior to each flight. At AD issuance EASA will determine that the task is simple enough and does not require complex tools nor complex instructions, which allows the Maintenance Organisation to authorise the person.

IF NOT INDICATED IN THE AD, THE FOLLOWING APPLIES:
145.A.30(j)4 or M.A.606(h)2 Personnel requirements, or CAO.A040(c)(2) Certifying staff.

In the case of aircraft operating away from a supported location the organisation may issue a limited certification authorisation to the pilot-in command/aircraft commander on the basis of the flight crew licence held, provided that the organisation ensures that sufficient practical training has been carried out to ensure that such person can accomplish the specified AD task to the required standard. The organisation’s manual shall include specific procedures for such authorisations, and in addition the task must be simple maintenance.

For AD actions performed by Pilot-Owner for aircraft subject to Part-M:

M.A.803 Pilot-owner authorisation

This is only applicable for other than complex motor-powered aircraft of 2 730 kg MTOM and below, which are not used commercially;
The accomplishment of an AD task by the Pilot-Owner is permitted only in the case where it is specifically allowed in the AD (* - see Note); and
Furthermore, it is only permitted to the Pilot-Owner under the conditions of M.A.803 (a) and (b) (limited Pilot-owner maintenance (Appendix VIII to Part-M)).

For AD actions performed by Pilot-Owner for aircraft subject to Part-ML:

ML.A.803 Pilot-owner authorisation

This is only applicable to aircraft not operated commercially, to balloons not operated under Subpart-ADD of Regulation (EU) 2018/395 or to sailplanes not operated under Subpart DEC of Regulation (EU) 2018/1976;
The accomplishment of an AD task by the Pilot-Owner is permitted only in the case where it is specifically allowed in the AD (* - see Note); and
Furthermore, it is only permitted to the Pilot-Owner under the conditions of ML.A.803 (a) and (b) (limited Pilot-owner maintenance (Appendix II to Part-ML)).

* Note: For ADs issued by EASA, when the flight crew / pilot-owner is entitled to carry out the AD task(s) subject to the applicable requirements, the AD will contain a text similar to the following:

The action(s) required by paragraph (x) of this AD may be accomplished, as appropriate: either by suitably authorised flight crew under the provisions of Commission Regulation (EU) No 1321/2014 145.A.30(j)3, M.A.606(h)1, or CAO.A.040(c)(1), as applicable; or by the pilot-owner under the provisions of M.A.803 or ML.A.803, as applicable, of the same regulation.

In respect of aircraft not subject to (EU) No 1321/2014, the State of Registry should consider if the national regulations allow the action(s) to be accomplished by the flight crew or pilot owner.

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Part-M

Part-M: General

Continuing airworthiness management for each type of operator/ aircraft

		CONTINUING AIRWORTHINESS MANAGEMENT
Commercial operations	Licenced air carriers [¹]	Continuing airworthiness shall be performed by a CAMO. Operator shall be CAMO approved (CAMO linked to the AOC).
Commercial operations	Commercial specialised operations or CAT operations other than licensed air carriers or commercial ATOs	Continuing airworthiness shall be performed by a CAMO. Operator shall obtain CAMO approval, or operator shall contract a CAMO
Other than commercial operations	Complex motor-powered aircraft [²]	Continuing airworthiness shall be performed by a CAMO. Owner shall contract a CAMO
Other than commercial operations	Other than complex motor-powered aircraft (CMPA) and limited operations [³]	Continuing airworthiness management may be performed by the owner. CAMO is not required.

[1] Licenced air carriers are EU air carriers holding an operating licence in accordance with Regulation (EC) 1008/2008

[2] Twin turboprop aeroplanes of 5 700 kg MTOM and below can be exempted by the Member State from complying with any requirements applicable to CMPA and shall instead comply with the requirements applicable to other than CMPA.

[3] Limited operations are defined in Regulation (EU) 1312/2014 Article 2(p).

The pre-flight inspection forms part of the essential requirements for air operation, as required in Annex V (point 6.2) of the ‘Basic Regulation’ (Regulation (EU) 2018/1139). Being relevant to the aircraft’s fitness for the intended flight, this essential requirement is implemented by the Commission Regulation (EU) 1321/2014 for continuing airworthiness in the following way:

Reference	Obligation	Who	Remark
M.A.201(d) ML.A.201(d)	Carry out pre-flight inspection satisfactorily	Part-M: Pilot-in-command or, in case of Licensed Air Carrier, a qualified staff under the responsibility of the operator (e.g. maintenance staff - see note) Part-ML: Pilot-in-command or a qualified person under the responsibility of the pilot-in-command
M.A.301(a)/ ML.A.301(a)	Ensure pre-flight inspection is carried out	Owner or CA(M)O (according to M.A.201/ML.A.201)
M.A.301(a)/ ML.A.301(a)	Ensure pre-flight inspection includes the actions necessary to ensure that the aircraft is fit to carry out the intended flight	Owner or CA(M)O (according to M.A.201/ML.A.201)	AMC M.A.301(a) points (1) and (2) elaborates those actions
M.A.301(a)/ ML.A.301(a)	If a/c managed by CA(M)O: Provide training to ensure that pre-flight inspection is carried out adequately [AMC M.A.301(a) point (3)]	CA(M)O	Pre-flight inspection training described in the CAME part 1.11 or CAE part D.6
Additional information:
M.A.712(b)/ CAMO.A.200(a)(3)/ CAO.A.100(b)	If a/c managed by CA(M)O: Ensure pre-flight inspection is subject to the quality system/compliance monitoring [AMC M.A.301(a) point (3)]	CA(M)O	This is important because the pre-flight inspection contributes in feeding the process of aircraft continuing airworthiness

Note:

As per the definition of ‘maintenance’ in article 2 (h) of Commission Regulation (EU) 1321/2014, ‘pre-flight inspection’ (as defined in article 2(j)) is not considered maintenance. Therefore, it does not require a certificate of release to service [M.A.201(d)/ML.A.201(d)].

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Do declared training organisations (DTO) need a CAMO/CAO and approved maintenance organisations?

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Airworthiness review

Can an airworthiness review certificate (ARC)/recommendation be issued after an airworthiness review with open findings?

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Can the extension of an ARC be anticipated more than 30 days?

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Can an Airworthiness Review Staff (ARS) perform an airworthiness review on an aircraft in which he/ she had released some maintenance as Certifying Staff (CS)?

To avoid possible conflict of interests, the ARS (Airworthiness Review Staff) should not be or have been involved in the release of the maintenance for the aircraft on which he or she intends to perform the airworthiness review (AR), except in one of the following cases:

Such maintenance has been released as part of the airworthiness review’s physical survey of the aircraft (e.g. release necessary after visual inspections requiring panel opening);
Such maintenance has been released as a result of findings discovered during the physical survey of the aircraft (defect rectification)
Note: cases 1 and 2 are justified by the fact that such specific maintenance activity is part of the AR and therefore does not require independence between maintenance and the AR.
Such maintenance has been released as part of the 100-h/annual inspection contained in the maintenance programme conducted together with the Airworthiness Review of the Part-ML aircraft:
- by an approved maintenance organisation (145.A.75(f) or CAO.A.095(c)(2)) (see also ML.A.901(b)(3)); or
- by independent certifying staff holding an ARS authorisation (see ML.A.901(b)(4)) for aircraft operated under Annex VII (Part-NCO) to Regulation (EU) No 965/2012 or, for balloons not operated under Subpart-ADD of Annex II (Part-BOP) to Regulation (EU) 2018/3951 or for sailplane, not operated under Subpart DEC of Annex II (Part-SAO) to Regulation (EU) 2018/1976.

Remark

From regulatory perspective, cases 1 and 2 are explicitly considered by ‘AMC M.A.707(a)’ and ‘AMC1 CAMO.A.310(a)’ [2nd bullet of point (5), respectively point (e)] for an ARS belonging to a CAMO also holding a AMO approval. Although not explicitly mentioned in any AMC, considering the Note above, the Agency understands that this principle is also permitted in other cases where the ARS happens to be also Certifying staff (including independent certifying staff).

Remark:
Iaw M.A.901(l) or ML.A.903(b), when the ARS is not Certifying Staff, he/she must be assisted by a Certifying Staff to release the maintenance mentioned in cases 1 and 2.

Is there any European requirement to maintain the back-to-birth traceability for any component fitted to an European aircraft?

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What does the term “detailed maintenance records” mean?

There has been a certain confusion about the understanding of “detailed maintenance records”, because this term is used in a different context for continuing airworthiness management and approved maintenance organisation (AMO).

“Detailed maintenance records” as defined in M.A.614, 145.A.55(c) or CAO.A.90(a) are required to be kept by an AMO (respectively Part-M/F organisation, Part-145 organisation or CAO with maintenance privileges). Maintenance organisations are required to retain all detailed records in order to be able to demonstrate that they maintained aircraft and components in compliance with applicable requirements (see also remark).

“Detailed maintenance records” as defined in M.A.305(e)(2) or ML.A.305(h)(1) are those records, coming from the AMO1 having performed maintenance, required to be kept by the owner/operator (or the CAMO or CAO with Continuing airworthiness management privileges when required by M.A.201 or ML.A.201) allowing to determine the aircraft configuration, the airworthiness status of the aircraft and all components installed, as well as to plan future maintenance as required by the AMP, based on the last accomplishment.

Consequently, the AMO should transmit to the owner/operator/CA(M)O a certain subset of the AMO maintenance records, including the certificates of release to service and repair/modification data related to the performed maintenance, so that the owner/operator/CA(M)O can demonstrate compliance with M.A.305 or ML.A.305.

Not all AMO maintenance records need to be transferred from the AMO to the owner/operator unless they specifically contain information relevant to aircraft configuration/status and future maintenance. Thus, incoming certificates of conformity, batch number references and individual task card sign-offs verified by and/or generated by the maintenance organisation are not required to be transferred to the owner/operator/CA(M)O. However, dimensional information contained in the task card sign-offs or work packages may need to be transferred and kept by the owner/ operator.

It is to be noted that the record-retention period requirements are slightly different for the AMO and the CAMO and CAO with Continuing airworthiness management privileges. The AMO shall retain the records for 3 years, whereas the CAMO and CAO with Continuing airworthiness management privileges has to retain their records until they are superseded by new information (equivalent in scope and detail), but not less than 3 years. The starting point in both cases is when the aircraft or component maintenance has been released.

Remark: It is considered a best practice as part of the AMO record-keeping system, (and it is also required by certain competent authorities) to record information (e.g. batch number or other tracking reference) relevant to the identification of all standard parts and material used during any maintenance. This practice may limit safety and industrial risks in the case where a batch is recalled by the manufacturer. Such record does not need to be transmitted to the owner/operator/CAMO/CAO with Continuing airworthiness management privileges.

*: Transmitted records is a subset of AMO maintenance records provided to the CA(M)O. Certain transmitted records do not need to be kept as a record by the CA(M)O such as EASA Form 1 for a component with no scheduled maintenance task selected and not subject to AD or modification/repair.

**: by new information equivalent in scope and detail
_______________________________________________________________________________________________________

¹Or pilot-owner [M.A.803 or ML.A.803], or independent certifying staff [M.A.801(b)point 1 or ML.A.801(b)(2)]

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Is there an obligation to keep the EASA Form 1 for on-condition components?

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AMP (Aircraft Maintenance Programme)

What are the main principles governing the development of the AMP under Part-ML?

For aircraft complying with Part-ML (refer to Article 3(2) of Regulation (EU) No 1321/2014, the AMP should be based either on the applicable ICA or on the Minimum Inspection Programme (MIP) defined in ML.A.302(d).

The owner, when she/he has not contracted the continuing airworthiness management to a CAMO or CAO [see ML.A.201(f)], should ‘declare’ the AMP assuming responsibility for its content. Such declared AMP does not need to be sent to the competent authority. Except for the mandatory requirements (see also remark below) the owner may decide, under his/her full responsibility, to deviate from the applicable scheduled maintenance recommendations (including ICA if the AMP is not based on the MIP) without the need to justify such deviation(s) (see GM1 ML.A.302).

If the aircraft is managed by a CAMO or CAO, such organisation should ‘approve’ the AMP. Deviations from the applicable scheduled maintenance recommendations (including ICA if the AMP is not based on the MIP) should be justified and properly recorded.

In both scenarios though (AMP declared by owner or approved by CAMO/CAO), when the AMP is not based on the MIP, the deviations to the applicable ICA shall not result in a less restrictive task than the corresponding MIP task. A clear overview of the different options for the development (including the source of information and potential customisation) and approval of such an AMP is provided by ‘GM1 ML.A.201’, ‘GM2 ML.A.302’.

In addition, the AMP shall be reviewed annually. For declared AMP, this review should be done by the person who performs the airworthiness review during its accomplishment (see AMC1 ML.A.302(c)(9)). For approved AMP, the review can be done either by the Airworthiness Review Staff (ARS) during the airworthiness review or by the CAMO itself.

If during the airworthiness review it is observed that there are discrepancies on the aircraft linked to deficiencies in the content of the aircraft maintenance programme, the AMP must be amended. The competent authority shall be informed in the case where the ARS does not agree with the measures taken to amend the AMP.

Remarks:

In accordance with ML.A.302 and in particular ML.A.302(c)(4), the AMP, declared or approved, shall in all cases include all the mandatory maintenance/continuing airworthiness requirements, such as repetitive Airworthiness Directives or the Airworthiness Limitation Section (ALS).

References:

Please refer also to ‘AMC2 ML.A.302’ (EASA Form AMP), ‘GM1 ML.A.302’ and ‘AMC1 ML.A.302(d)’ (content of MIP).

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When does the calendar interval for the next aircraft or component maintenance task start?

In a normal scenario :

The date of signing the certificate of release to service (CRS) should be considered to be the date of the accomplishment.
The next due date should be calculated using this date.

However, there may be different considerations that render the normal scenario no longer applicable. For example:

Case 1: The interval of the maintenance task has been previously subject to a one-time extension using an approved procedure included in the aircraft maintenance programme (refer to Appendix I to AMC M.A.302 point 4) normally called ‘permitted variation’ or ’tolerance’. In this case the next due date should be calculated using the previous due date (as opposed to accomplishment date) or as agreed by the competent authority.

For aircraft regulated by Part-ML the situation is different when applying the tolerance of 1 month foreseen in ML.A.302(d), the next interval shall be calculated from the accomplishment date (refer to ML.A.302(d)(1) and AMC1 ML.A.302(d)).

Case 2: The maintenance task refers to a component maintenance task, for example the landing gear overhaul. In this case the start of the interval would be the date of the release to service after the overhaul of the landing gear or in some particular cases when specified in the maintenance data the interval may start from the date of installation on aircraft.

Case 3: The task is released as part of a maintenance check/visit, where the duration of the check/visit is significant compared to the interval of the task. In this case, there may be significant difference between date of accomplishment and date of release. For example, a check/visit that lasts for 2 months and an inspection that has an interval of 3 months. In this case, either the task is carried out on the last days of the maintenance check/visit and the next due date is calculated from the CRS, or the task is carried out at the beginning of the visit and the next due date should be calculated from the date of accomplishment.

There may be other examples, but the key principle is to use sound engineering judgment and the guidance provided in the Instructions for Continuing Airworthiness to calculate the next due date.

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When should I revise my Aircraft Maintenance Programme (AMP)?

Part-M:

In accordance with M.A.302(h), the Aircraft Maintenance Programme (AMP) shall be subject to ‘periodic reviews’ and amended accordingly when necessary.

This means that the owner/operator/CA(M)O should review at a regular interval:

new/modified maintenance instructions by the TC holder,
modifications and repairs embodied in the particular a/c, which may require compliance to additional maintenance instructions (by Design Approval Holder),
in-service experience collected for the particular a/c or for the fleet and
changes in the type and specificity of operations.

Such a review allows to determine if an AMP revision is necessary to still comply with the obligations of M.A.302(h), and ensure that the AMP continues to be valid in light of the operating experience. As a minimum, point (3) of AMC M.A.302 states it should be at least annually.

However, this should not prevent amending the AMP outside of this formal periodic review, when a specific need arises. This may depend for example on in-service experience (e.g. adverse trend), nature of instruction revisions (e.g. significant reduction of TBO (time between overhaul)), the extent of instruction revisions (amount of affected tasks) as well as source of instruction revisions (e.g. MRBR, ALS, etc.)

When a revision of the ALS (Airworthiness Limitation Section) introduces a new or more restrictive task, EASA has the policy to issue an AD (Airworthiness Directive). Such an AD would typically mandate on one side the revised task accomplishment and on the other side the revision of the AMP itself, together with a compliance time for these two actions.

However, in accordance with point (3) of AMC M.A.302, EASA recommends to review the AMP as soon as possible in this case to avoid a disconnection between accomplished maintenance task(s) and maintenance task(s) listed in the AMP.

If the aircraft’s continuing airworthiness is being managed by a CA(M)O, the CA(M)E (Continuing Airworthiness Management Exposition/Combined Airworthiness Exposition) should describe the AMP revision policy (including ‘periodic review’) under point 1.2 [Appendix V to AMC M.A.704], point 1.2 [AMC1 CAMO.A.300] or point D.3 [AMC1 CAO.A.025].

Remark: In the case where the source documents are amended without having an effect on the AMP content, it is acceptable to use an indirect approval procedure (if granted by the competent authority in accordance with M.A.302(c)) to amend the relevant source document references in the AMP.

Part-ML:

ML.A.302(c)(9) requires an annual review of the AMP.
For aircraft regulated by Part-ML the review of the AMP may be carried out with the airworthiness review (AR) of the aircraft by the person who performs such AR.

Such a review allows to determine if an AMP revision is necessary to still comply with the obligations of ML.A.302(c) or ML.A.302(d) and ensure that the AMP or MIP continues to be valid in light of the operating experience. As a minimum, ML.A.302(c)(9) states it should be at least annually.

However, in accordance with ML.A.302(c)(9), EASA recommends to review the AMP as soon as possible in this case to avoid a disconnection between accomplished maintenance task(s) and maintenance task(s) listed in the AMP.

Remark:

AMP regulated by Part-ML are declared by the owner or approved by the CAMO or CAO (ML.A.302(b)).

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Can a competent authority require the owner/CAMO/CAO to include national requirements in the Aircraft Maintenance Programme (AMP), based on M.A.302(d)(1)?

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How is it possible to escalate AMP task intervals?

Part-M

General:

Some general expectations for escalation initiatives are described in the following paragraph:

a) It should be ensured that the AMP continues to be valid in light of the operating experience [M.A.302(h) – see FAQ n.47406].

b) It should form part of the analysis of the effectiveness of the AMP (if required by M.A.301(e)),

c) The AMP should include a procedure to manage the escalation of established intervals [AMC M.A.302 point (4) and point (2) of AMC M.B.301(c)].

Supported by a formal reliability programme if required by M.A.302(g) or voluntarily implemented [AMC M.A.302(d) point (6)] or collection and analysis of in-service experience.

‘Appendix I to AMC M.A.302 and AMC M.B.301(b)’ provides detailed guidelines for the integration of this information into the AMP.

d) If there is a CA(M)O involved, those points also have to be emphasised within the CA(M)E, as specified in Appendix V to AMC1 M.A.704, AMC1 CAMO.A.300 or AMC1 CAO.A.025.

Two different cases:

The escalation of AMP task intervals falls into the alternative instructions proposed by the owner/CA(M)O [M.A.302(e)] and distinguishes in the following cases:

Case 1:

Escalation of safety-related task intervals, which consist of all mandatory tasks (Airworthiness Limitation Section) as well as certain non-mandatory tasks issued by the DAH (Design Approval Holder) such as various MRBR (Maintenance Review Board Report) tasks [see note below], tasks related to emergency equipment, critical components…

Case 2:

Escalation of non-safety-related task (e.g. non-safety related MRBR task or a task recommended by a Service Letter) intervals

Note:
In cases, where the aircraft type has been subjected to the MRB process, the following MRBR tasks should be considered safety-related:

Failure Effect Category (FEC) ‘5’ (evident safety) and ‘8’ (hidden safety) tasks (systems and powerplant)
SSI (Structural Significant Item) tasks
L/HIRF (Lightning / High Intensity Radiated Field) tasks (as applicable)
Stand-alone EWIS tasks (EZAP procedure)

Escalation approval:

The approval of a task escalations is addressed separately for each case:

Regarding case 1:

1.1 Escalation of mandatory tasks represents a change of the initial type design and therefore must be discussed and agreed between the DAH and the Agency*.
1.2 The AMP revision proposal and the information used to substantiate the escalation of non-mandatory tasks [AMC M.B.301(b)(6)] have to be evaluated by the competent authority [AMC M.B.301(b) point (2)]. Following a positive evaluation, a direct approval of the AMP revision will be issued by the competent authority, as stated in M.A.302(e).

Regarding case 2:

An indirect approval of the AMP through a CA(M)O is possible and described in more detail in FAQ n.19061.

* Exception may exist under certain condition for Two Star CMR (Certification Maintenance Requirement) (see AMC 25-19).

Remarks:

In all cases, task de-escalation may need to be considered based on the supporting data [AMC M.A.302(g) point (4)].
Escalation should not be confused with ‘permitted variations’ to AMP intervals, which applies to a unique aircraft for a unique occasion [‘Appendix I to AMC M.A.302 point (4)].

Part-ML

General:

Some general expectations for escalation initiatives are described in the following paragraph:

a) It should be ensured that the AMP continues to be valid in light of the operating experience [[ML.A.302(c)(9) – see FAQ n.47406].

b) The effectives of the AMP should be assessed at least by an annual review [ML.A.302(c)(9)].

c) The AMP may include additional maintenance actions [ML.A.302(c)(3)] supported by collection and analysis of in-service experience.

‘GM1 ML.A.302(c)(3)’ provides detailed guidelines for the integration of this information into the AMP.

d) If there is a CA(M)O involved, those points also have to be emphasised within the CA(M)E, as specified in Appendix V to AMC M.A.704, AMC1 CAMO.A.300 or AMC1 CAO.A.025.

Two different cases:

The escalation of AMP task intervals falls into the alternative instructions proposed by the owner/CA(M)O [GM1 ML.A.302(c)(2)(b)] and distinguishes in the following cases:

Case 1:

Escalation of safety-related task intervals, which consist of all mandatory tasks (Airworthiness Limitation Section) as well as certain non-mandatory tasks issued by the DAH (Design Approval Holder), tasks related to emergency equipment, critical components…

Case 2:

Escalation of non-safety-related task (e.g. task recommended by a Service Letter) intervals

Escalation approval:

The approval of the escalation is carried out by the CAMO or CAO [ML.A.302(b)(2)]. For declared AMP no approval is needed [ML.A.302(b)(1)].

Remarks:

In all cases, task de-escalation may need to be considered based on the supporting data.
Escalation should not be confused with ‘permitted variations’ to AMP intervals, which applies to a unique aircraft for a unique occasion [GM1 ML.A.302(c)(3)].

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What kind of alternative (other than escalation) or additional instructions can be introduced in the AMP?

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CAMO (Continuing Airworthiness Management Organisation)

Are deputies to nominated persons required in CAMO or CAO?

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Under which condition can a CAMO or CAO use the indirect approval procedure to amend AMP (Aircraft Maintenance Programme) task(s) under Part-M?

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Does the CAMO or CAO compliance monitoring/quality system need to be subject to internal audit?

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The requirement to establish a procedure to assess non-mandatory modifications/inspections pursuant to CAMO.A.315(b)(4) refers to the “use of the organisation’s safety risk management process”. What does this mean?

The CAMO has the obligation, for complex motor-powered aircraft and aircraft used by air carriers licensed in accordance with Regulation (EC) No 1008/2008, to establish a procedure to assess non mandatory modifications and inspections (e.g. Service Bulletins).

This assessment should result in a decision to implement or not the recommendation provided in such non-mandatory information (e.g. perform the inspection, embody the modification, amend the aircraft maintenance programme (AMP)).

This assessment procedure should take into consideration several aspects, as the case may be, including but not limited to:

the applicability to the operator’s fleet (e.g. type of operating environment, utilization, aircraft configuration);
achievement of operator’s safety objectives;
mitigating potential aviation safety risks already identified by the operator;
mitigating potential aviation safety risks not yet apparent to the operator but identified by other operators or TC/STC holder, for aircraft in a similar operational environment;
reliability improvement of the aircraft and components; and
improvement of the effectiveness of the AMP.

In case of potential aviation safety risks, the CAMO should review the hazard(s) identified in the recommendation and the proposed maintenance action and its timeframe (i.e. timeline to embody the modification or amend the AMP). This is the main purpose of the expression “making use of the organisation’s safety risk management process”. If necessary, the CAMO will perform a safety risk assessment (e.g. in terms of probability and severity of consequences) and a review of the related mitigations.

Typically, SBs are issued for technical purposes (as mitigation or safety risk control). For instance, a SB could provide the following:

an elimination of an identified hazard by the embodiment of a modification, or
reducing the safety risk (i.e. the severity and/or likelihood) of the consequences of an identified hazard by the embodiment of a modification, or
reducing the likelihood of the consequences of an identified hazard by performing repetitive inspections.

Since SBs are also used for other purposes (e.g. optional equipment installation, commercial retrofit) and not only for potential safety-related situations, it is not required to use safety risk management process for each SB.

The CAMO should use its safety risk management process to determine if the hazard identified in the SB applies to the managed fleet and what the associated risk is, and/or whether the proposed action (modification/inspection) are applicable, effective and reasonable. For clarity, it is not intended that the CAMO should redo the safety assessment performed by the design approval holder; the CAMO assessment should be tailored to its fleet and related operations.

The referred CAME procedure for the assessment of non-mandatory modifications and inspections should ideally describe the decision-making process and mandate to record the decision taken and its justifications (e.g. based on considerations of costs vs benefits such as safety or reliability).

The decision to embody a modification may require the change management process to be followed to ensure proper coordination between the aircraft operator, the CAMO and the approved maintenance organisation. For example, a modification that affects Mass and Balance, requires maintenance check flights, introduces revised flight manual procedures, maintenance manual procedures, changes to the AMP, which needs to be managed to ensure proper dissemination of the information, training, review of existing hazards, and review of risk assessment, as applicable.

Yes

Quality system

Does the Part-145 or Part-CAO quality system need to be subject to monitoring?

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Certification of maintenance

With respect to blend out repairs, is it required to record the depth and area dimensions of material removed during a blend out repair or is it sufficient to simply record that the damage has been repaired as per the SRM?

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Can the subcontractor of a Part-145 or Part-CAO organisation release maintenance?

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Release to service of NDT tasks by Part-145 or Part-CAO organisations

This answer is separated in two tables. One table is for organisation holding a Part-145 approval and the second table is for organisations holding a Part-CAO approval.

Part-145:

Part-145 organisation	Certifying staff required	Qualification system	General Release procedure	Release procedure for an NDT inspection
Aircraft (class A)	The release of the aircraft maintenance carried out under A class rating has to be performed by certifying staff holding a Part-66 licence. (B1 or B3 or C or L certifying staff under the organisation’s A rating.)	Licencing of personnel has to follow Part-66 regulation.	The release is either on the aircraft technical log or issuing an aircraft release to service statement.	A Part-145 organisation holding an A approval rating on a particular aircraft type and having in its approved scope of work NDT inspections for this aircraft type. This organization needs to have part-66 certifying staff and NDT personnel qualified in accordance with 145.A.30(f). In this case the NDT inspector performs the NDT task and signs off the work order. The aircraft is released by appropriately qualified B1, B3, C or L certifying staff under the organisation’s A rating. Please note that the release may include not only the NDT task but also the associated tasks (removal of panels, blankets, wires, re-installation, etc), or the NDT task may be part of a base maintenance check.
Engines Class B	The release of the engine maintenance carried out under B class rating has to be performed by engine’s certifying staff.	The certifying staff is qualified following the procedures established by the organisation in compliance with the competent authority requirements. Part-66 licence is not required.	The release of works performed under class B is done on an EASA Form 1 (or by means of an internal release document when this component is for the organisation’s own use and the organisation has in place the related internal procedures in the MOE).	A Part-145 organisation holding a B rating approval on a particular engine type and having in its approved scope of work NDT inspections for this engine type. This organization needs to have “engine” certifying staff (qualified in accordance with company procedures) and NDT personnel qualified in accordance with 145.A.30(f). In this case the NDT inspector performs the NDT task and signs off the work order. The engine certifying staff releases the works performed to the engine (including NDT inspection) on an EASA Form 1.
Components Class C	The release of the component maintenance carried out under C class rating has to be performed by components certifying staff (CCS).	The certifying staff is qualified following the procedures established by the organisation in compliance with the competent authority requirements. The CCS is not required to have a Part-66 licence.	The release of works performed under class C is done on an EASA Form 1 (or by means of an internal release document when this component is for the organisation’s own use and the organisation has in place the related internal procedures in the MOE).	A Part-145 organisation holding a C rating approval on a particular component and having in its approved scope of work NDT inspections for this component. This organization needs to have CCS and NDT personnel qualified in accordance with 145.A.30(f). In this case the NDT inspector performs the NDT task and signs off the Work Order / Engineering Order. The CCS releases the works performed to the component (including NDT inspection) on an EASA Form 1.
Specialised services	The release of the maintenance carried out under D1 class rating has to be performed by “specialised services” certifying staff.	The certifying staff is qualified following the procedures established by the organisation in compliance with EN4179, Part-66 licence is not required.	The release of works performed under class D1 rating is done on an EASA Form 1 or using another form of release to service (other than aircraft release to service) as defined by the organisation in the MOE in compliance with 145.A.50 and approved by the competent authority.	A Part-145 organisation holding a D1 approval on a particular NDT method. The approved scope of work will be NDT inspections on this method. This organisation needs to have NDT certifying staff qualified in accordance with 145.A.30(f). In this case the NDT certifying staff performs and releases the NDT task on an EASA Form 1 or using another form of release to service (other than aircraft release to service) as defined by the organisation in the MOE in compliance with 145.A.50 and approved by the competent authority.

Note: In case of non-EU organisations approved by the EASA in accordance with Part-145, the Part-66 licence could be read as “Part-66 or national licence in accordance with Part-145 Appendix IV”

Part-CAO:

Part-145 organisation	Certifying staff required	Qualification system	General Release procedure	Release procedure for an NDT inspection
Aircraft (class aeroplanes, helicopter, airships, balloons or sailplanes)	The release of the aircraft maintenance carried out under A class rating has to be performed by certifying staff holding a Part-66 licence.	Licencing of personnel has to follow Part-66 regulation.	The release is either on the aircraft technical log or issuing an aircraft release to service statement.	A Part-CAO organisation holding an aeroplanes, helicopter, airships, balloons or sailplanes particular aircraft type or and having in its approved scope of work NDT inspections for this aircraft type. This organization needs to have part-66 certifying staff and NDT personnel qualified in accordance with CAO.A.035(f). In this case the NDT inspector performs the NDT task and signs off the work order. The aircraft is released by appropriately qualified B1, B3 or L certifying staff under the organisation’s aeroplanes, helicopter, airships, balloons or sailplanes rating. Please note that the release may include not only the NDT task but also the associated tasks (removal of panels, blankets, wires, re-installation, etc), or the NDT task may be part of a base maintenance check.
Engines or Components other than complete engines Class Components	The release of the engine maintenance carried out under components class rating has to be performed by ‘engine’s’ or ‘components other than complete engines‘ certifying staff.	The certifying staff is qualified following the procedures established by the organisation, Part-66 licence is not required.	The release of works performed under class components is done on an EASA Form 1 (or by means of an internal release document when this component is for the organisation’s own use and the organisation has in place the related internal procedures in the CAE).	A Part-CAO organisation holding a components rating approval on a particular engine type or ‘components other than complete engines‘ and having in its approved scope of work NDT inspections for this engine type. This organization needs to have “engine” or ‘components other than complete engines‘ certifying staff (qualified in accordance with company procedures) and NDT personnel qualified in accordance with CAO.A.035(f). In this case the NDT inspector performs the NDT task and signs off the work order. The engine or ‘components other than complete engines‘ certifying staff releases the works performed to the engine or ‘components other than complete engines‘ (including NDT inspection) on an EASA Form 1.
Components Class C	The release of the component maintenance carried out under C class rating has to be performed by components certifying staff (CCS).	The certifying staff is qualified following the procedures established by the organisation in compliance with the competent authority requirements. The CCS is not required to have a Part-66 licence.	The release of works performed under class C is done on an EASA Form 1 (or by means of an internal release document when this component is for the organisation’s own use and the organisation has in place the related internal procedures in the MOE).	A Part-145 organisation holding a C rating approval on a particular component and having in its approved scope of work NDT inspections for this component. This organization needs to have CCS and NDT personnel qualified in accordance with 145.A.30(f). In this case the NDT inspector performs the NDT task and signs off the Work Order / Engineering Order. The CCS releases the works performed to the component (including NDT inspection) on an EASA Form 1.
Specialised services	The release of the maintenance carried out under ‘Specialised Services’ class rating has to be performed by “specialised services” certifying staff.	The certifying staff is qualified following the procedures established by the organisation in compliance with EN4179, Part-66 licence is not required.	The release of works performed under class ‘Specialised Services’ rating is done on an EASA Form 1 or using another form of release to service (other than aircraft release to service) as defined by the organisation in the CAE in compliance with CAO.A.070(a) and approved by the competent authority (AMC1 CAO.A.070 (a)(1)).	A Part-CAO organisation holding a ‘Specialised Services’ approval on a particular NDT method. The approved scope of work will be NDT inspections on this method. This organisation needs to have NDT certifying staff qualified in accordance with CAO.A.035(f). In this case the NDT certifying staff performs and releases the NDT task on an EASA Form 1 or using another form of release to service (other than aircraft release to service) as defined by the organisation in the CAE in compliance with CAO.A.070 and approved by the competent authority.

Note: In case of non-EU organisations approved by the EASA in accordance with Part-145, the Part-66 licence could be read as “Part-66 or national licence in accordance with Part-145 Appendix IV”

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Maintenance data

Shall the maintenance data be available and controlled at all times, even if there is no maintenance work going, or shall it be available only during the performance of maintenance?

Maintenance data has direct influence on many processes of the approved maintenance organisation (AMO) and contributes to demonstrate the overall capability of the organisation to perform maintenance.

The maintenance data either can be arranged directly by the AMO or provided by the customer/operator as specified by 145.A.45(a), M.A.609 or CAO.A.055(a). In both cases, the AMO should demonstrate that the maintenance data used, regardless of the source, is up-to-date. To discharge this responsibility, a procedure should be established to:

(a) control the amendment status of any documents being used;

and

(b) regularly check that all amendments are being received, e.g. by subscribing to a document amendment scheme (sufficient in case of direct access to the maintenance data through the DAH/OEM. The subscription to the maintenance data distribution system of the customer/operator is insufficient, additional independent verifications through the original author shall be done).

When the maintenance data is arranged directly by the AMO it shall be available and controlled continuously.

There are certain situations when the maintenance data can be obtained only through the customer/operator. One of the examples would be the maintenance data for the large aircraft. The maintenance data coming from the TC holder is usually customised because of the model/configuration/modification/order of aircraft, so it is normally not possible for the AMO to have this customised maintenance data directly from TC holder without having an aircraft of that type under the contract.

When the maintenance data is provided by the customer/operator, it shall be held and controlled by the AMO during maintenance on the concerned aircraft/component. Whenever the maintenance data is not available or not current, the maintenance shall not be performed and released.

Additionally, as part of the obligation for maintenance records, used maintenance data shall be:

recorded (in compliance with 145.A.55(c), M.A.614(c) or CAO.A.090(b))
Remark: Manuals issued by the (S)TC (Supplementary Type Certificate) holder such as AMM and CMM do not need to be stored as a record. Recording the revision status of such manual may be sufficient [AMC 145.A.55(c), AMC M.A.614(c)]; and
accessible for auditing purpose

to demonstrate that the organisation worked in compliance with their respective requirements.

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Personnel requirements

Can a certification maintenance requirement (CMR) be performed by the Flight Crew before flight?

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What is the meaning of the Protected Rights in the Appendix IV to Part-145?

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What are the training requirements for personnel within a Part-145 organisation, other than those contained in Part-66?

Requirement	Reference
The accountable manager shall demonstrate a basic understanding of Part-145.	145.A.30(a) point 3.
The person or group of persons nominated responsible for ensuring that the organisation complies with Part-145 (including the Quality Manager) shall be able to demonstrate relevant knowledge, background and satisfactory experience related to aircraft or components maintenance as applicable, a working knowledge of Part-145,	145.A.30(b) point 3.
The organisation shall establish and control the competence of personnel involved in any maintenance, airworthiness review management and/or quality audits in accordance with a procedure and to a standard agreed by the competent authority. In addition to the necessary expertise related to the job function, competence must include an understanding of the application of human factors and human performance issues appropriate to that person's function in the organisation. This should include also: Fuel Tank Safety training (AMC3 145-A-30(e) and Appendix IV to AMC 145.A.30(e) and 145.B.10(3)). EWIS training (AMC 20-22)	145.A.30(e) and associated AMC/GM. Appendix IV to AMC 145.A.30(e) and 145.B.10(3). AMC 20-22.
The organisation shall ensure that personnel who carry out and/or control a continued airworthiness non-destructive test of aircraft structures and/or components 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 to this paragraph those personnel specified in paragraphs (g) and (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.	145.A.30(f) and AMC 145.A.30(f).
By derogation to paragraphs (g) and (h), in relation to the obligation to comply with Annex III (Part-66), the organisation may use certifying staff qualified in accordance with the following provisions: 1. For organisation facilities located outside the Community territory certifying staff may be qualified in accordance with the national aviation regulations of the State in which the organisation facility is registered subject to the conditions specified in Appendix IV to this Part. 2. For line maintenance carried out at a line station of an organisation which is located outside the Community territory, the certifying staff may be qualified in accordance with the national aviation regulations of the State in which the line station is based, subject to the conditions specified in Appendix IV to this Part. 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 aircraft commander and/or the flight engineer on the basis of the flight crew licence held. However, the organisation shall ensure that sufficient practical training has been carried out to ensure that such aircraft commander or flight engineer can accomplish the airworthiness directive to the required standard. 4. In the case of aircraft operating away from a supported location the organisation may issue a limited certification authorisation to the commander and/or the flight engineer on the basis of the flight crew licence held subject to being satisfied that sufficient practical training has been carried out to ensure that the commander or flight engineer can accomplish the specified task to the required standard. The provisions of this paragraph shall be detailed in an exposition procedure. 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 shall be reported to the competent authority within seven days of the issuance of 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.	145.A.30(j) and associated AMC/GM. Appendix IV to Part-145.
In addition to the appropriate requirements of 145.A.30(g) and (h), the organisation shall ensure that certifying staff and support staff have an adequate understanding of the relevant aircraft and/or components, or both, to be maintained and of the associated organisation procedures. In the case of certifying staff, this shall be accomplished before the issue or reissue of the certification authorisation.	145.A.35(a) and AMC 145.A.35(a).
The organisation shall ensure that all certifying staff and support staff are involved in at least six months of actual relevant aircraft or component maintenance experience in any consecutive two-year period.	145.A.35(c) and AMC 145.A.35(c).
The organisation shall ensure that all certifying staff and support staff receive sufficient continuation training in each two-year period to ensure that such staff have up-to-date knowledge of relevant technology, organisation procedures and human factor issues.	145.A.35(d) and AMC 145.A.35(d).
The organisation shall establish a programme for continuation training for certifying staff and support staff, including a procedure to ensure compliance with the relevant paragraphs of 145.A.35 as the basis for issuing certification authorisations under this Part to certifying staff, and a procedure to ensure compliance with Annex III (Part 66).	145.A.35(e) and AMC 145.A.35(e).
Except where any of the unforeseen cases of 145.A.30(j)(5) apply, the organisation shall assess all prospective certifying staff for their competence, qualification and capability to carry out their intended certifying duties in accordance with a procedure as specified in the exposition prior to the issue or reissue of a certification authorisation under this Part.	145.A.35(f) and AMC 145.A.35(f).
The holder of a category A aircraft maintenance licence may only exercise certification privileges on a specific aircraft type following the satisfactory completion of the relevant category A aircraft task training carried out by an organisation appropriately approved in accordance with Annex II (Part-145) or Annex IV (Part-147). This training shall include practical hands on training and theoretical training as appropriate for each task authorised. Satisfactory completion of training shall be demonstrated by an examination or by workplace assessment carried out by the organisation.	145.A.35(n) and AMC 145.A.35(n).
The holder of a category B2 aircraft maintenance licence may only exercise the certification privileges described in point 66.A.20(a)(3)(ii) of Annex III (Part-66) following the satisfactory completion of (i) the relevant category A aircraft task training and (ii) six months of documented practical experience covering the scope of the authorisation that will be issued. The task training shall include practical hands on training and theoretical training as appropriate for each task authorised. Satisfactory completion of training shall be demonstrated by an examination or by workplace assessment. Task training and examination/assessment shall be carried out by the maintenance organisation issuing the certifying staff authorisation. The practical experience shall be also obtained within such maintenance organisation.	145.A.35(o) and AMC 145.A.35(o).
Pre-flight inspections (when the 145 organisation has an agreement with an operator) It should be demonstrated that the personnel carrying out pre-flight inspections have received appropriate training for the relevant pre-flight inspection tasks based on the operator’s CAME.	ML.A.301(a) or M.A.301(a) and AMC M.A.301(a)

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Part-66

Get a Part-66 licence

What are the Part-66 licence categories?

In a Part-145 approved organisation, the different categories of Part-66 licences are:

LICENCE CATEGORY	For certifying the release to service of work performed on aircraft:	What:
A	Minor scheduled line maintenance and simple defect rectification Divided into the following subcategories: A1 Aeroplanes Turbine; A2 Aeroplanes Piston; A3 Helicopters Turbine; A4 Helicopters Piston.	Line Maintenance
B1	Maintenance on aircraft structure, power plant and mechanical and electrical systems, avionic systems requiring simple tests to prove their serviceability and no troubleshooting Divided into B1.1 for turbine aeroplanes, B1.2 for piston engine aeroplanes, B1.3 for Turbine helicopter and B1.4 for piston engine helicopter	Line Maintenance
B3	Maintenance on aeroplane structure, power plant and mechanical and electrical systems; and on avionics systems requiring only simple tests to prove their serviceability and not requiring troubleshooting limited to non-pressurized aeroplanes of 2 000 kg MTOM and below.	Line Maintenance
B2	Maintenance performed on avionic and electrical systems and electric and avionics tasks within powerplant and mechanical systems requiring only simple test and minor scheduled line maintenance and simple defect rectification	Line Maintenance
B2L	The same as B2 but limited to the systems endorsed on the licence: Divided into the following ‘system ratings’: communication/navigation (com/nav), instruments, auto flight, surveillance, airframe systems.	Line Maintenance
L	Maintenance on aircraft structure, power plant and mechanical and electrical systems; radio, Emergency Locator Transmitters (ELT) and transponder systems; and work on other avionics systems requiring simple tests to prove their serviceability Divided into the following subcategories: L1C: composite sailplanes, L1: sailplanes, L2C: composite powered sailplanes and composite ELA1 aeroplanes, L2: powered sailplanes and ELA1 aeroplanes, L3H: hot-air balloons, L3G: gas balloons, L4H: hot-air airships, L4G: ELA2 gas airships, L5: gas airships other than ELA2.	Line Maintenance
C	Base maintenance C with respect to complex motor-powered aircraft and C with respect to other than complex motor-powered aircraft	Line Maintenance
	Support staff for:
B1	Maintenance on aircraft structure, power plant and mechanical and electrical systems, avionic systems requiring simple tests to prove their serviceability and no troubleshooting (subdivided into B1.1 for turbine aeroplanes, B1.2 for piston engine aeroplanes, B1.3 for Turbine helicopter and B1.4 for piston engine helicopter)	Base Maintenance
B2	Maintenance on avionic and electrical systems and electric and avionics tasks within power plant and mechanical systems requiring only simple test and minor scheduled line maintenance and simple defect rectification	Base Maintenance
B2L	The same as B2 but limited to the systems endorsed on the licence: communication/navigation (com/nav), instruments, auto flight, surveillance, airframe systems.
B3	Maintenance on aeroplane structure, power plant and mechanical and electrical systems; and on avionics systems requiring only simple tests to prove their serviceability and not requiring troubleshooting limited to non-pressurized aeroplanes of 2 000 kg MTOM and below.	Base Maintenance
L	Maintenance on aircraft structure, power plant and mechanical and electrical systems; radio, Emergency Locator Transmitters (ELT) and transponder systems; and work on other avionics systems requiring simple tests to prove their serviceability Divided into the following subcategories: L1C: composite sailplanes, L1: sailplanes, L2C: composite powered sailplanes and composite ELA1 aeroplanes, L2: powered sailplanes and ELA1 aeroplanes, L3H: hot-air balloons, L3G: gas balloons, L4H: hot-air airships, L4G: ELA2 gas airships, L5: gas airships other than ELA2.	Base Maintenance

See points 66.A.3 and 66.A.20 of Annex III (Part-66) to Regulation (EU) No 1321/2014 can be found on the Agency website https://www.easa.europa.eu/regulations#regulations-continuing-airworthi… or in the eRules https://www.easa.europa.eu/document-library/easy-access-rules/easy-acce…)

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How to get an EASA Part-66 Licence (Category B1 or B2)?

Regulation (EU) 1321/2014 does not require any medical examination before applying for a Part-66 licence.

In the past some medical criteria were proposed in JAR-66, but these were removed in order to avoid conflicts with national rules. JAR 66.A.50 had requirements on:

use of alcohol at work,
effects of medicines,
physical conditions, vision, ability to see colours,
mental conditions.

Part-66 has only a provision to suspend, limit or revoke licences in case of carrying out maintenance or issuing a certificate of release to service when adversely affected by alcohol or drugs [66.B.500 point(7)].

Current 145.A.30(e) requests certifying staff to receive a human factor training and GM 1 145.A.30 (e) gives guidance about the elements of the training to be imparted:

4 - Human performance & limitations
4.1    Vision
4.2    Hearing
4.3    Information-processing
4.4    Attention and perception
4.5    Situational awareness
4.6    Memory
4.7    Claustrophobia and physical access
4.8    Motivation
4.9    Fitness/Health
4.10 Stress
4.11 Workload management
4.12 Fatigue
4.13 Alcohol, medication, drugs
4.14 Physical work
4.15 Repetitive tasks / complacency

Common sense recommends the certifying staff not to exercise the privileges of their certification authorisation if they know or suspect that their physical or mental condition renders them unfit to exercise such privileges (impact to the safe maintenance operations). In addition such recommendation may be covered and rendered mandatory by the national requirements of the Member State where you exercise your privileges. Typical examples are for intoxication (alcohol, drugs, etc.).

It is therefore recommended that you inform the management of your maintenance organisation:

as you should not deviate from the national law;
as the organisation shall establish and control the competence of personnel; (145.A.30(e) – necessary expertise related to the job function);
as the organisation shall have a human performance programme in place (145.A.35(e)); and
as the ICAO safety management system encourages to identify hazards and risks.

Please find an agreement with your company in order to list the maintenance tasks that you are allowed to carry out without jeopardising the aircraft safety.

Note: The same reasoning as explained above applies for any medical condition.

For personnel studying a qualification at a University or a degree in a country outside of the EU: I am studying aeronautics and I wish to obtain an EASA Part-66 licence? May I get a credit or may I get a licence based on my degree?

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Which documentation is required to support the application demonstrating compliance with the experience requirements?

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Where do I gain the required basic maintenance experience? Is it mandatory to gain the required maintenance experience in an EASA approved Part-145 organisation?

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I work as a mechanic in the military field on aircraft being also certified for civil operations. In order to obtain the Part-66 licence, why do I need additional experience of civil aircraft maintenance as required by 66.A.30(e) on top of my experience in the military field?

As stated in 66.A.30(e), for mechanics having a military background and seeking a Part-66 licence, the objective is to ensure adequate understanding of the civil aircraft maintenance environment, not only because of possible different aircraft technologies, but also because of practices linked to the civil environment.

Not only the technology or systems of the civil aircraft might differ from the military aircraft version configuration (e.g. no video entertainment system; no sliding chutes; different fuel or electrical systems) but the experience gained in the military environment might also significantly differ from the scope of work of the civil maintenance organisation, its procedures and policies (e.g. use and meaning of the certificate of release to service - EASA Form 1, standard parts, store and tools procedures, use of the maintenance documentation such as ADs, SB, SIL…, quality and safety management system; human factor aspects, continuing airworthiness record systems…).

In addition the interaction with the customers (i.e. the airliners) induces new practices such as use of the aircraft technical log book, MEL, aircraft defect rectification and deferment of items; use of customer documentation (e.g. MPD, MRB, SRM, IPC); interaction with the crew; how to behave with the passengers; special procedure such as (re)fuelling, de-icing /anti-icing; communication with the tower or moving on the apron.

Finally, the requirements for the continuing airworthiness of the aircraft might significantly evolve in the civil environment. To name a few, the following items can be reminded: ADs, SBs, operational directives, EASA requirements; records and archives; repairs and modifications (use of data, EASA/FAA rules; dual-release); special inspections (e.g. CPCP, EWIS); approved maintenance programme and its effectiveness / reliability; occurrence reporting; understanding of MSG-3 methods …

The military regulations widely differ from country to country, with certain countries having military rules similar to the EU ones, while others have very different rules. The 12-month additional civil maintenance experience average (as per AMC 66.A.30(e)), has been agreed by the Member States and accepted as a standard way to demonstrate compliance with the rule to achieve mutual recognition and adequate degree of standardisation.

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I have completed my EASA Part-66 modules for B1 and I have passed all the exams, but I still lack experience to get my licence. Is there a time limit to get the licence ? Will the certificate expire in a few years if I do not get the experience?

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Categories of a Part-66 licence

I hold a Category A1 Part-66 licence. What are the requirements to extend my licence to Category B1.1?

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I already hold a Part-66 licence and I would like to include an additional basic (sub)category? Which additional (sub)modules are required to be passed for the addition of that new (sub)category?

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Type ratings of a Part-66 licence

What is a difference between examination and assessment? Why are there two different examination standards, respectively in Part-66 Appendix III, points 4 and 5?

Examination is a written form of demonstration of a certain level of theoretical knowledge by the student based on achievement of the learning objectives, usually performed on completion of a theoretical training course or a portion of a course. The student shall demonstrate, to the levels identified in the table in Appendix III, the detailed theoretical knowledge of the aircraft’s applicable systems, structure, operations, maintenance, repair, and troubleshooting according to approved maintenance data, as well as the use of manuals and approved procedures, including the knowledge of relevant inspections and limitations. The standard, format, pass mark, etc. are defined in Appendix III, 4.1. The examination shall be performed by the appropriately trained and approved examiner.

Assessment is a practical form of measuring the competence of the student by evaluating three major factors associated to the learning objectives: knowledge, skills and attitude, usually performed on completion of a practical training course. The assessment should focus on the competencies relevant to the aircraft type and its maintenance. The principles on how to perform the competence assessments are given in the AMCs to Part-66, Appendix III. The assessment shall be performed by appropriately trained and approved assessors.

What is the intention of the requirement regarding the assessment of the OJT. What is the nature of the assessment for an OJT? What are the differences between practical assessment and OJT assessment? What are the objectives of the OJT assessment?

The practical assessment addresses the practical portion of any type training whereas the OJT assessment addresses the additional practical experience necessary to gain in a true maintenance environment as part of the first type rating in a (sub)category, as illustrated by the table below:

	PRACTICAL ASSESSMENT	OJT ASSESSMENT For the purpose of 66.A.45(c)
What/who is assessed:	Candidates following practical element of training.	Completeness of the OJT.
What/who is assessed:	Reference: 66.A.45 (a)&(b); Appendix III, 4.2.; AMC Appendix III	Reference: 66.A.45 (c); Appendix III, section 6; AMC to Section 6 of Appendix III
Function of assessor:	To perform the final evaluation of the knowledge, skills and attitude of the trainee following the practical element of the type training	To conduct the final assessment of the completed OJT, whereas the candidate’s competence is indirectly justified.
Function of assessor:	Reference: Appendix III 4.2.; AMC Appendix III	Reference: Appendix III, 6.; AMC to Section 6 of Appendix III 8.
Organisation :	Part-147 Approved maintenance environment (Part-145, M.A. Subpart F with A rating, manufacturer) under the Part-147 approval Defined maintenance environment as described in the direct approved procedure by the competent authority (66.B.130)	Always in a maintenance organisation approved under Part-145 with an aircraft rating
Organisation :	Reference: Appendix III 1(b)	Reference: Appendix III 6.; AMC to Section 6 of Appendix III 1.
Objectives:	To evaluate if the candidate has gained the required competence in performing safe maintenance, inspections and routine work according to the aircraft documentation and other relevant instructions and tasks as appropriate for the type of aircraft.	To confirm the completion of the required diversity and quantity of OJT, based on the supervisor(s) reports and feedback. It is sufficient that the completion of individual OJT tasks is confirmed by the direct supervisor(s), without being necessary the direct evaluation of the assessor.
Objectives:	Reference: Appendix III, 3.2.	Reference: AMC to Section 6 of Appendix III 7. & 8.
Type of assessment:	The assessment may be: diagnostic (prior to a course), formative summative (partial or final evaluation) performed task-by-task performed as a group of tasks partly executed on simulation devices performed as a final assessment	Continuous during OJT (confirmed by the direct supervisor) Summative, as a final evaluation of the completeness of the OJT (based on the supervisor(s) reports and feedback)
Type of assessment:	Reference: AMC to Part-66 Appendix III 2)	Reference: AMC to Section 6 of Appendix III to Part-66
Qualification of the assessor:	The assessment shall be performed by designated assessors appropriately qualified. It means that the assessors should demonstrate training and experience on the assessment process being undertaken and be authorised to do so by the organisation. Guidance about the qualification is given in AMC to Part-66 Appendix III 3.)	The OJT shall be assessed by designated assessors appropriately qualified. It means that the assessors should demonstrate training and experience on the assessment process being undertaken and be authorised to do so by the organisation. Guidance about the qualification is given in AMC to Part-66 Appendix III 3.)
Qualification of the assessor:	Reference: Appendix III 4.2.; AMC to Part-66 Appendix III 3.)	Reference: Appendix III 6.; AMC to Part-66 Appendix III 3.)
Procedure included in:	Part-147 MTOE	Part-145 Maintenance organisation exposition (chapter 3.15) or “one-off” direct approval
Procedure included in:	Reference: Appendix III 1(b); Part-147	Reference: AMC 145.A.70 (a)

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(OJT) What is the meaning of the following statement in Part-66 Appendix III, Section 6: “The final assessment of the completed OJT is mandatory and…”?

The completeness of the whole OJT process shall be assessed. The intent of the requirement is not to suggest that:

there should be an assessment performed by the assessor on top of every task monitored by the supervisor; and/or
at the very end of the OJT programme, there should be a comprehensive hands-on assessment of the candidate on a real aircraft as an additional and ultimate evaluation

All report(s) or feedback from the supervisor(s) having monitored every actual job task performance or any other source of information (use of manuals and procedures; observance of safety measures, warnings and recommendations; adequate behaviour in the maintenance environment), the designated assessor should be in a position to:

ensure that the OJT procedure was fully met (in terms of objective and content); and
check that the competence of the candidate was positively assessed.

In case of doubt, the assessor may decide to proceed him/herself to an additional evaluation of the candidate or perform a gap analysis when the OJT procedure is not fully met such as an insufficient number of tasks or diversity of tasks or unclear supervisor’s report regarding the candidate’s performance. The supervisor should not sign the actual task if the person did not achieve the required competence in safe task performance.

Note: It is worth being reminded here that OJT addresses:

the first type rating in a (sub)category of aircraft; and
subsequently addresses young mechanics (e.g. “newcomers”) or mechanics having no experience in that new (sub)category of aircraft (e.g. extension of the license).

AMC to Section 6. of Appendix III to Part-66 gives more clarification about the assessment process and the function of the assessor:

“It is sufficient that the completion of individual OJT tasks is confirmed by the direct supervisor(s), without being necessary the direct evaluation of the assessor”, and
“The function of the assessor, as described in Section 6 of Appendix III to Part-66, is to conduct the final assessment of the completed OJT. This assessment should include confirmation of the completion of the required diversity and quantity of OJT and should be based on the supervisor(s) reports and feedback”.

It is left to the decision of the competent authority how to comply with this requirement: the AMC as suggested by the Agency aims at avoiding additional burden, duplication or over-regulation while proposing a simple final evaluation process.

The endorsement of the first aircraft type rating, within a given category/sub-category, requires satisfactory completion of the corresponding On-the-Job-Training (ref. 66.A.45(c)).

The OJT shall be approved by the competent authority who has issued the licence (ref. Part 66, Appendix III, sec. 6).

It shall be carried out in a maintenance organisation approved under Part-145 with A rating or and the procedures for OJT should be included in the exposition (MOE chapter 3.15 “OJT procedure”, approved by the competent authority of the maintenance organisation. However, since these procedures are approved by the competent authority of the maintenance organisation, and providing training is not one of the privileges of a maintenance organisation, they can only be used when the licensing authority (competent authority issuing the license) is the same as the competent authority of the maintenance organisation. In other cases, it is up to the licensing authority to decide whether it accepts such procedures for the purpose of approving the OJT (ref. AMC to Section 6 of Appendix III to Part-66).

For the Part-145, whose principal place of business is located outside the EASA Member states, the competent authority of the maintenance organisation is EASA. In such case, the OJT procedures cannot be included in the MOE, due to the fact that EASA is not a licensing authority.

The possibility still exists in this case that a licensing authority may directly approve OJT procedures, which have to be included in a separate document outside (and not being part) of the MOE.

Consequently, personnel working in these AMOs, or the AMOs wishing to support its staff on this matter, should:

Option A: apply directly to the licensing authority who has issued the license for the approval of an OJT (to be proposed in a document outside the MOE). This option should normally be considered by organisations and not by individuals.
Option B: find an agreement to follow an already approved OJT at another organisation, which was approved by the same licensing authority who has issued the license. Possibility also exists to follow an OJT which was approved by any other licensing authority, however in such a case the final acceptance of this OJT for the purpose of endorsing the first type rating in the license remains at the sole discretion of the competent authority issuing the license.

It is recommended that prior to starting any OJT, the licensing authority who has issued the license is contacted to verify its acceptance of any possible intended option.

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Privileges of a Part-66 licence

I am the holder of a B1.2 licence (i.e “aeroplane piston”). Can I exercise my privileges for piston-engine non-pressurised aeroplanes1 of 2000 kg MTOM and below (i.e. category B3)?

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Can I have endorsed in my Part-66 licence aircraft types for which the Basic Regulation is not applicable?

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Point 66.A.20(b)(2) requires in the preceding 2 years, 6 months of experience or to meet the provisions for the issue of the appropriate privileges. What does it mean? Does it affect the validity of the Part-66 licence?

The “validity” of the Part-66 licence is not affected by point 66.A.20(b)(2). The licence itself remains valid 5 years from the last renewal.
Nevertheless, compliance with point 66.A.20(b)(2) is required to ensure that the maintenance privileges are exercised by certifying staff that hold sufficient recent experience.
If you do not meet this point anymore, you lose your rights to exercise your privileges of certifying staff or support staff.
Therefore, as holder of an aircraft maintenance licence, to exercise your certification privilege in accordance with 66.A.20(b)(2), please ensure:

• You have accumulated 6 months of experience in the previous 2 years;

Note: see also AMC 66.A.20(b)(2) for possible reductions of experience, in particular for independent certifying staff. Demonstration of experience should be made on the particular or similar aircraft. Guidance on ‘similar’ aircraft is also provided in AMC 66.A.20(b)(2).

• You can demonstrate that in the last 2 years, you have met the provisions for the issue of appropriate privileges, which means (refer to 66.A.45), as applicable to the case:

1) going to a type-training course again (the need for OJT has to be assessed on case-by-case basis);

2) when the aircraft endorsement does not require type training (aircraft belonging in Group 2, 3 or 4):

       a) pass a type evaluation, including practical assessment;
or
        b) when no type evaluation is required for aircraft endorsement, for example:
            - a B2/B2L license endorsed with a full group 3 or 4 rating; or
            - for L-category licences (other than L5),
being able to demonstrate, in the last 2 years, practical experience, which shall include a representative cross section of maintenance activities relevant to the licence subcategory (B2/B2L, L1, L1C, L2, etc.)

Note: “A representative cross section of maintenance activities” means representative cross-section of the tasks listed in Appendix II to AMC to Annex III (Part-66) “Aircraft Type Practical Experience and On-the-Job Training - List of Tasks”. “Demonstrate” means having a record thereof, such as a logbook.
Note: GM 66.A.20(b)2 will be reviewed and amended according to this interpretation through rulemaking task RMT.0735.

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As a category A certifying staff at line, can my authority allow me to carry out more tasks than those specified in AMC 145.A.30(g)?

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Part-147

Basic training

Is it possible to grant a Part-147 approval to a training organisation which intend to conduct only training on one or only several modules?

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I have completed a part of my basic training course (including some module examinations) in an approved Part-147 organisation. I’m moving to another country and would like to continue my basic training in a Part-147 organisation located in the country where I move in. Is this possible? What will happen with my certificates? Can I get the maximum reduction of the experience required for the Part-66 licence?

There are several scenarios possible depending on the particular case. Here are some most probable cases for category A, B1, B2, B2L, B3 or L:

Case No 1 (baseline – standard case): The applicant completes the whole basic knowledge course (including the training, practical assessments and basic modules examinations) in an approved Part-147 maintenance training organisation.

Result: The Certificate of Recognition (CoR) of the basic course completion is issued by the organisation. The applicant can apply for the Part-66 licence with 1 or 2 years of maintenance experience (66.A.30).

Case No 2: The applicant completes the basic training in two different Part-147 AMTO (including the examinations).

Result: The CoRs for the successful examination of each individual module are issued (by different AMTO), but not the CoR for the basic course completion. The applicant does not benefit from the experience reduction and have to fulfil the requirement of 2 or 3 years of experience (if recognised as skilled worker) or 1, 2, 3 or 5 years (66.A.30).

It may happen that some of the competent authorities would give the complete credit on experience in case the applicant can prove that: the training completed in different organisation covers in total the Appendix I or Appendix VII syllabus; and
all the practical assessments are performed and passed successfully; and
all interactions between the modules have been correctly addressed; and
there was a right proportion of theoretical and practical training for each subject.

As this demonstration requires a significant investment, the applicant is invited to directly contact the competent responsible for performing such an investigation.

Case No 3: The applicant has completed a full basic training course in one approved Part-147 organisation. Unfortunately, the candidate was not in a position to successfully pass the full examination process (all modules) in that organisation and had to pass the missing portion of the examination in another approved Part-147 organisation.

Result: In this case the applicant would receive a CoR for basic training only as well as the CoRs related to the modules successfully passed in that approved Part-147 organisation. The examination for the missing modules may be successfully passed in another approved Part-147 organisation(s) with issuance of the related CoRs thereof. The combination of all these CoRs may be sufficient for the competent authority to recognise the training course as successfully “completed” and to grant the maximum credit for the experience (only 1 or 2 years needed, see case No 1) for the issue of the license.

Case No 4: The applicant did not attend a Part-147 basic training course but only took examinations in one or more approved Part-147 organisation(s).

Result: The applicant would receive several CoRs for the successful examination of individual modules from one or more approved Part-147 organisations. No credit of experience as per 66.A.30 will be granted (except for skill workers – 2 or 3 years). Standard 1, 2, 3 or 5 years of experience will be required.

Further information is given in AMC to Appendix III to Part-147 “Certificates of Recognition referred to in Annex IV (Part-147) – EASA Forms 148 and 149.

Examination

In case the answer you were looking for in this FAQ section is not available: you might submit your enquiry here

Air Operations - General

In the definition of ‘commercial operation’ published in Art. 2 of Regulation (EU) 965/2012 (introduced by the amending Reg. (EU) 2018/1975), what is the meaning of the term “control”?

Reference: Regulation (EU) No 1178/2011, Regulation (EU) No 965/2012

These terms refer to certain legal concepts used in aviation safety regulations, in particular Reg. (EU) No 1178/2011 on aircrew and Reg. (EU) No 965/2012 on air operations.

'Grandfathering' designates the legal recognition and acceptance of certificates issued on the basis of national legislation by national authorities prior to the entry into force of a specific regulation. For example, in Reg. (EU) No 1178/2011, the conditions for the grandfathering of JAR-compliant and non-JAR-compliant pilot licences and medical certificates are set forth in its Articles 4 and 5. In Reg. (EU) No 965/2012, the conditions for grandfathering of EU-OPS AOCs are set forth in Article 7(1).

Grandfathering measures are included in the Cover Regulation to assist Member States in the transition from national rules to unified EU rules. In the case of aircrew licensing, provisions on grandfathering consider some national certificates issued in compliance with given regulations and by a certain date as being in compliance with the new Aircrew Regulation (i.e. Reg. (EU) No 1178/2011).

A 'transition measure' is a provision helping the national competent authorities and regulated entities to gradually adapt to the new EU rules. Several examples can be found in the Aircrew Regulation, such as in Article 11c (in relation to the obligation of Member States regarding the transfer of records and certification processes of those organisations for which the Agency is the competent authority) and in Article 4 (1) — the obligation of Member States to adapt grandfathered pilot licences to the new format by a certain date.

The 'opt-out' is a form of transition measure applicable to Member States. Opt-out provisions allowed Member States to decide not to implement an EU regulation or certain provisions thereof for a certain period of time, delaying the date of application of the new regulation (or certain provisions thereof) within that Member State. For example, the opt-out provisions contained in the Aircrew and Air Ops regulations required the Member State to notify the European Commission and EASA of the 'opt-out', describing the reasons for such derogation and the programme for the phasing out of the opt-out and achieving full implementation of the common requirements.

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What is the difference between 'entry into force' and 'date of applicability' in the Cover Regulations?

Many Commission Regulations adopted in EASA domains contain two different dates, usually under the heading “entry into force”. The example below is from Regulation (EU) No 965/2012 on air operations:

Article 10
Entry into force
1. This Regulation shall enter into force on the third day following that of its publication in the Official Journal of the European Union.
It shall apply from 28 October 2012.

The entry into force of an EU regulation represents the date when the regulation has legal existence in the EU legal order and in the national legal order of each Member State.

It is common practice that the regulation enters into force 20 days after its publication in the Official Journal of the EU. That is the case when the legislator simply uses the expression “This Regulation enters into force on the 20th day after its publication in the Official Journal of the European Union.” Shorter periods are also used, as was the case in the example above.

Sometimes the date of entry into force is also the date of applicability of a regulation, meaning that from the date when it enters into force, the regulation is also applicable; it can be fully invoked by its addressees and is fully enforceable.

However, due to the complexity of the domains that are regulated, a period of time may be needed between the date the regulation enters into force, i.e. it legally exists, and the date it can actually be applied, i.e. the date when it is enforceable and the legal rights and obligations can be effectively exercised.

This period of time (vacatio legis) is deliberately introduced for Member States, competent authorities, operators, organisations, licence holders and any other addressees or beneficiaries of the regulations to prepare their systems, processes, procedures, documentation, etc. for compliance with the new rules.

Vacatio legis is also a period given for the addressees of the regulation to adjust to the upcoming rights and obligations and take the necessary measures to benefit from the legal effects of the regulation, namely for the purposes of mutual recognition of certificates and approvals in the aviation internal market.

In those cases, it is common practice of the legislator to establish two different dates under the article on entry into force. One date establishes the legal existence of the act (entry into force); the second date establishes the date when it becomes applicable (applicability).

The date of applicability therefore represents the date from which the regulation can produce rights and obligations on the addressees and can be directly enforced towards the courts, administrations, national governments, etc. This means that before the date of applicability, obligations or privileges can neither be exercised nor enforced.

The same understanding is shared by the Legal Service of the Commission, which has also clarified in EASA Committee that the privileges provided for in a regulation can only be exercised as of the applicability date chosen by the legislator. Persons subject to the relevant regulation (including national aviation authorities) may prepare themselves for such an effective date (adapting their procedures and practices), but can neither enjoy the privileges nor enforce the obligations.

Legal consequences

This means that Member States cannot start delivering authorisations, approvals, certificates, etc. issued in accordance with the new regulations and at the same time producing all the legal effects of the regulation from the date of entry into force of the regulation, but only from the date of its applicability. However, during the gap period existing between the date of entry into force and the date of applicability, Member States and competent authorities can prepare the process towards the issuance of such authorisations, approvals, and any other certificates in accordance with the new provisions.

In addition, during the period of vacatio legis, an option that Member States and competent authorities can consider, in order to avoid issuing certificates on the last day before the date of applicability, is to issue the new certificates in accordance with the new regulation while clearly indicating in those certificates that they are only valid as of a certain date that would coincide with the date of applicability of the regulation on the basis of which those certificates are issued. This means that those new certificates may be issued, but are not yet effective and cannot be mutually recognised among Member States until the common date of applicability established by the regulation. Until they become effective, licence holders, organisations and operators should still retain and use the certificates already issued under the previous regime. Competent authorities are only obliged to accept the new certificates once the regulation has become applicable.

Implementing rules (IRs) are binding in their entirety and used to specify a high and uniform level of safety and uniform conformity and compliance. They detail how to comply with the essential requirements of the Basic Regulation and regulate the subject matters included in its scope. The IRs are adopted by the European Commission in the form of Regulations. EU law is directly applicable (full part of Member States' legal order).

Detailed implementation aspects are included as Certification Specifications (CS) or Acceptable Means of Compliance (AMC).

Acceptable Means of Compliance (AMC) are non-binding. The AMC serves as a means by which the requirements contained in the Basic Regulation and the IRs can be met. The AMC illustrate a means, but not the only means, by which a requirement of an implementing rule can be met. Satisfactory demonstration of compliance using a published AMC shall provide for presumption of compliance with the related requirement; it is a way to facilitate certification tasks for the applicant and the competent authority. However, NAAs and organisations may decide to show compliance with the requirements using other means. Both NAAs and the organisations may propose alternative means of compliance (AltMoCs). ‘Alternative Means of Compliance’ are those that propose an alternative to an existing AMC. Those AltMoC proposals must be accompanied by evidence of their ability to meet the intent of the IR. Use of an existing AMC gives the user the benefit of compliance with the IR.

Read more on the difference between AMC and AltMoC.

Certification Specifications (CS) are non-binding technical standards adopted by EASA to meet the essential requirements of the Basic Regulation. CSs are used to establish the certification basis (CB) as described below. Should an aerodrome operator not meet the recommendation of the CS, they may propose an Equivalent Level of Safety (ELOS) that demonstrates how they meet the intent of the CS. As part of an agreed CB, the CS become binding on an individual basis to the applicant.

Special Conditions (SC) are non-binding special detailed technical specifications determined by the NAA for an aerodrome if the certification specifications established by EASA are not adequate or are inappropriate to ensure conformity of the aerodrome with the essential requirements of Annex VII to the Basic Regulation. Such inadequacy or inappropriateness may be due to:

the design features of the aerodrome; or
where experience in the operation of that or other aerodromes, having similar design features, has shown that safety may be compromised.

SCs, like CSs, become binding on an individual basis to the applicant as part of an agreed CB.

Guidance Material (GM) is non-binding explanatory and interpretation material on how to achieve the requirements contained in the Basic Regulation, the IRs, the AMCs and the CSs. It contains information, including examples, to assist the user in the correct understanding and application of the Basic Regulation, its IRs, AMCs and the CSs.

Frequently Asked Questions: FAQs are published on the EASA website and cover a wide range of material. Although the information contained in the FAQs is a summary of existing law or procedures, it may contain the results of a more complex interpretation of IR or other rules of law. In such cases there is always an internal quality consultation within the Agency prior to the publication of the FAQ on the website. The EASA FAQs are necessary to share information and enable to get a common understanding.

The FAQs are not additional GM.

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Does Reg. (EU) No 965/2012 on air operations also apply to non-commercial operations?

References: Regulation (EU) No 965/2012 on air operations as amended by Regulation (EU) No 800/2013; Reg. (EC) No 216/2008

Yes, non-commercial operations with aeroplanes and helicopters are covered by Reg. (EU) No 965/2012 on air operations. The applicable rules are determined by the complexity of the aircraft being used: Annex VI (Part–NCC) applies to non-commercial operations with complex motor-powered aircraft) and Annex VII (Part–NCO) applies to non-commercial operations with other-than-complex motor-powered aircraft.

The definition of complex motor-powered aircraft is found in Article 3 of Reg. (EC) No 216/2008. Pursuant to Article 140(2)(a) of Regulation (EU) 2018/1139 (the New Basic Regulation), ‘complex motor-powered aircraft’ shall still be understood as a reference to point (j) of Article 3 of Regulation (EC) No 216/2008. This is a transitional provision until not later than 12 September 2023, when the implementing rules adopted on the basis of Regulations (EC) No 216/2008 and (EC) No 552/2004 shall be adapted to this Regulation. The definition is as follows:

“complex motor-powered aircraft' shall mean:

(i) an aeroplane:

with a maximum certificated take-off mass exceeding 5 700 kg, or
certificated for a maximum passenger seating configuration of more than nineteen, or
certificated for operation with a minimum crew of at least two pilots, or
equipped with (a) turbojet engine(s) or more than one turboprop engine, or

(ii) a helicopter certificated:

for a maximum take-off mass exceeding 3 175 kg, or
for a maximum passenger seating configuration of more than nine, or
for operation with a minimum crew of at least two pilots,

or

(iii) a tilt rotor aircraft”.

The definition for 'commercial operation' is in Article 2 of Regulation (EU) No 965/2012:

“(1)(d) 'commercial operation' means any operation of an aircraft, in return for remuneration or other valuable consideration, which is available to the public or, when not made available to the public, which is performed under a contract between an operator and customer, where the latter has no control over the operator”.

Training flights fall under either Part-NCC or Part-NCO, depending on the complexity of the aircraft used for the non-commercial operations.

In addition, Part-SPA applies to any operation requiring a specific approval (e.g. low visibility operations, transport of dangerous goods, performance-based navigation and more).

Finally, Annexes II (Part-ARO) and III (Part-ORO) contain the authority requirements and respectively the organisation requirements. Annex III applies to operators of complex motor-powered aircraft, both commercial and non-commercial.

Reference: Regulation (EU) No 965/2012 on Air Operations, Annex III (Part-ORO); Regulation (EU) No 1321/2014 on continuing airworthiness, Part-M

1. Continuing airworthiness management

The EU licensed air carrier hereafter referred to as ‘the operator’, needs to consider both the relevant Part-ORO rules that will become fully applicable on 29 October 2014 and the applicable Part-M requirements. For these operators, the Part-M Subpart-G approval is an integral part of the AOC (as defined in Part-M, M.A.201(h)).

The Part-M requirements have not yet been amended to align with the management system framework adopted for air operations. However the operator should ‘scrutinise’ all its activities under its hazard identification and risk management processes, including the continuing airworthiness activities. It is the operator’s responsibility to ensure that hazards entailed by any continuing airworthiness management task are subject to the applicable hazard identification procedures and that related risks are managed as part of the operator’s management system procedures.

A crew member is considered to be acclimatised to the time zone of the reference time for the first 48 hours.

In the following example there are 4 departure places: A, B, C and D and the crew member is in a known state of acclimatisation all the time.

between A and B there is a 2-hour time difference
between A and C – a 4 hour-time difference
between A and D – a 6-hour time difference

Day 1: The crew member starts acclimatised at A and finishes at B. The reference time is the local time at A, because the crew member is acclimatised at A and reports at A. The time difference between A and B is 2 hours. That means that after resting at B, the crew will be considered acclimatised at B.

Day 2: The crew member reports at B acclimatised to the local time at B for an FDP to C. At C the crew member has a rest period and becomes acclimatised to C. He/she has now covered 4-hour time difference, but in 2 days.

Day 3: The crew member reports at C acclimatised to the local time at C for an FDP to D. At D the crew member has a rest period and becomes acclimatised to D. He/she has now covered 6-hour time difference.

Day 4: The crew member reports again considered to be acclimatised at D. The local time at D is the reference time. The FDP between D and A covers 6-hour time difference. Crossing 6-hour time difference in one day (one FDP) induces time zone de-synchronisation. If the rotation finishes at A, the rest requirements in CS FTL.1.235 (b)(3)(i) are applicable.

Unknown state of acclimatisation

After the first 48 hours of the rotation have elapsed, the crew member is considered to be in an unknown state of acclimatisation.

The crew member only becomes acclimatised to the destination time zone, if he/she remains in that destination time zone for the time established in the table in ORO.FTL.105 (1).

During that time the crew member may have the rest in accordance with CS FTL.1.235(b)(3) and/or take other duties that end in different time zones than the first arrival destination, until he/she becomes acclimatised in accordance with the values in the table in ORO.FTL.105(1). In the case of duties to different time zones, the state of acclimatisation should be determined in accordance with GM1 ORO.FTL.105(1) (d)(3).

There are no specific provisions and conditions for such changes except in unforeseen circumstances, where, on the day, a Commander may use the provisions of Commander’s Discretion:

to continue with an FDP which exceeds the maximum FDP that the crew will operate or reduces the minimum rest period, or
to reduce the actual FDP and/or increase the rest period, in case of unforeseen circumstances which could lead to severe fatigue.

The operator may not plan or change an FDP at any time such that it exceeds the maximum applicable FDP.

FTL rules build upon the predictability of rosters so that crews can plan and achieve adequate rest (ORO.FTL.110 (a) and (g)). Operators are expected to plan sufficient capacity, at their operating bases, to deal with disruptions normally expected in daily operations using the specific FTL provisions (e.g. stand-by, reserve). Therefore, FDP changes after reporting should be an infrequent event as such changes can create roster instability and may generate fatigue. An aircrew member remains at all times under the responsibilities set out in CAT.GEN.MPA.100 (c)(5) to report unfit to fly, if s/he suspects fatigue which may endanger flight safety.

If changes to planned duties are to be made on the day of operation, all applicable limits apply: in particular the limits established pursuant to ORO.FTL. 205(b), (d), (e) or ORO.FTL.220. If a duty has not been planned with an operator’s extension under ORO.FTL. 205(d), it cannot be changed into a duty with such extension on the day of operation.

In addition, the operator must ensure that the impact on forward duties and days off, and importantly on cumulative limits, is accounted for.

It is possible during other-standby to assign a duty that will start after the rostered end of the standby period.

Duties assigned during other-standby should in principle start within the operator’s defined response time from the call. For example, a cabin crew while on home standby between 08:00h and 14:00h (as planned in the roster) receives a call at 13:55 h to report for duty at 14:55 h since the operator’s response time is 60 min. The response time between the call and reporting is considered a continuation of the standby, notwithstanding the rostered end of the standby; this time also includes travelling to the reporting point.

Operators describe their procedures and practices regarding standby, including reporting after the rostered standby period ends, in the OM-A. In doing so, they take into account that the Regulation provides a number of cumulative protections to crew member from excessive periods of combined standby and duty:

Operators shall only use the rostered standby availability period to place their call for duty. ORO.FTL.105 (25) defines standby as the period of time during which a crew member is required by the operator to be available to receive an assignment for a flight;
The maximum duration of other-standby is 16 hours. In its OM-A however, the operator may specify shorter periods considering its type of operation and the impact of the time spent on standby on the duty that may be assigned. Under the obligations of ORO.FTL.110 (b & e), operators must carefully evaluate what duration of standby is safely allowable within their particular operation;
The combination of standby and FDP do not lead to more than 18 hours awake time (see FAQ # 60);
The maximum FDP is reduced, if the standby period ceases after the first 6 hours (or 8 hours in case of extended FDP);
A crew member is always able to consider whether his/her duties on board an aircraft will be performed with the necessary level of alertness (CAT.GEN.MPA.100(c))

Any operator needs to demonstrate to the competent authority that their personnel has acquired at least the knowledge as per the syllabus in AMC1 ORO.FTL.250.

In essence, the fatigue management training is a competency-based training. The operator should identify what training and competences are needed for each personnel group: aircrew, instructors, rostering and management staff to perform their roles effectively, and what means of measuring the level of competency attained by each person who receives the training is available.

For example, a fatigue management instructor must have the training required by AMC1 ORO.FTL.250. The operator may, in addition to that, require that the instructor also complete training normally required for FRM inspectors in accordance with AMC5 ARO.GEN 200(a) (2).

Recommended fatigue management training topics for specific groups of employees can be found in the ICAO Doc 9966 Manual for the Oversight of Fatigue Management Approaches/Second Edition 2016.

Operators who aim to establish a system for fatigue risk management (FRM), should consider including the following additional subjects, for aircrew, FSAG members, FRM instructors, FRM auditors, managers, according to their functions:

the science behind FRM;
requirements of Part-ORO with respect to FRM;
components of the FRM of that particular operator and its functioning;
- FRM predictive, reactive and proactive processes
- roster fatigue metrics
- fatigue safety performance indicators
employees’ responsibilities with respect to the FRM;
use of fatigue reporting systems and implementing mitigations;
collection of fatigue data (both subjective and objective) to feed the FRM system.

The content and frequency of fatigue management training should be proportional to the operator’s fatigue risk exposure. For example, a scheduled airline and an on-demand night cargo operator are likely to establish different syllabus and frequency for their aircrew training. Also, an airline with crew members commuting long hours to/from their home base, should particularly focus on the use of company’s airport or hotel crew rooms for fatigue mitigation of disruptive schedules when providing fatigue management training.

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Reporting point ORO.FTL.105 (2): The global COVID-19 pandemic necessitated, on a number of occasions, a change to the typical aircrew reporting point. How should the operators address this change?

Aircrew typically used to report for duty at a crew room, at their home base or at outstation. The global COVID-19 pandemic caused disruptions in flight operations and necessitated, on a number of occasions, a change to the typical aircrew reporting point. Here below are some considerations that operators and aircrew should account for when addressing such change.

Notification to crew members. The operator must inform the crew about any change of the reporting point prior to operating as this is part of operator’s responsibilities under ORO.FTL.110.

Travelling time to the reporting point. Due to the change of reporting point, the otherwise duty time may turn into travelling time, thus extending the usual travelling time that a crew member is accustomed or prepared for. Therefore, the operator should make sure that the impact of the change of reporting point on traveling time and consequently on crew fatigue is not significant. The operator’ SMS has to manage the change of reporting point by assessing the potential negative impact on aircrew fatigue levels, based on evidence of adequate time frames and/or a comparison between the time necessary to report to the new point and the typical reporting point. In assessing the impact, the operator should account for additional operational factors e.g. standby call out times. The operator should address reporting at a place other than a crew room in the OM.

Commencement of duty. Duty starts from reporting for duty at the reporting point designated by the operator e.g. when the crew member checks-in in a crew room. In cases where the crew member is required by the operator to commence an activity prior to entering a crew room or a non-public area of an airport, so as to obtain flight documents at a check-in counter or ticket office, pass a security checkpoint or update the EFB, the duty starts at the point of commencing this activity. At airports where the crew members can access the non-public area or reach the departing gate through more than one security checkpoints, the operator should make sure that commencement time is the same for the same duty.

Aircrew briefing. The time for aircrew briefing is a duty time no matter where it takes place. If the briefing takes place at the gate where other people are also present, the operator should arrange for a secluded place considering security matters among other things. The size of the crew should not prevent crew members from talking to each other without disturbing and being disturbed. If the briefing takes place on board the aircraft, the operator should ensure that certain conditions are present, such as running APU/GPU, no disturbance from ground personnel or cleaning staff. Where the operator provides EFB, the briefing material should already be uploaded to it or if, new material is to be downloaded, the crew must be provided with means to do so.

Reporting times. The operator should specify in the OM reporting times that account for the type of operation, ground duties, size and type of the aircraft and the airport conditions (GM1 ORO.FTL.205(a)(1)). Ground duties include pre-flight duties (briefings; provision of documentation; transport to the aircraft parking stand, etc.).

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Individual crew members’ records of flight time and duty periods ORO.FTL.245, (see also ORO.FTL.105):

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Must the time for all training at the behest of the operator be entered in the schedule of the crew members and recorded?

To any training at the behest of the operator regardless of the method (e-learning¹) or self-study or otherwise) that an aircrew member is assigned to by the operator the following applies:

It is a duty and the time spent on training task constitutes a duty period.
It cannot be considered a rest period or a day free of all duty or an annual leave period (ORO.FTL.105).

E-learning¹ or self-study may be included as a single duty period in the CM roster with start and end times or assigned as a number of hours to be used over certain time (week(s) or month(s)), by the crew member to study the training material, in parts or at once, at the crew member discretion.

When assigning a number of hours, the operator should notify the crew member concerned in advance, specifying the allocated hours and time period for completion of the training. The training methods described above should comply with all daily or cumulative duty limits and rest requirements of Commission Regulation (EU) No 965/2012 and of Council Directive 2000/79/EC of 27 November 2000 (WTD), considering the period allocated for completion². The policy and description on how these training methods are managed should be clearly documented in the operations manual (OM). As part of their shared responsibilities with regard to crew fatigue, the crew members should manage their time and tasks considering other assigned duties and rest requirements as per ORO.FTL.115 (b).

As part of their shared responsibilities with regard to crew fatigue, the operator should ensure that the training duties are assigned in a way that enables crew members to fulfil their flight duties to a satisfactory level of safety under all circumstances. The operator should in particular provide rest periods of sufficient time prior to the next flight duty/duties and an adequate number of hours and period of time to enable a successful fulfilment.

¹ ICAO Circular 356 definition: E-Learning – is the delivery of a learning, training or education programme by electronic means.

² ORO.FTL.205; ORO.FTL.210; ORO.FTL.235; CS FTL.1.235; WTD Annex Clause 8 & 9.

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Passenger Safety

Use of baby bassinets on board

Reference: Certification Specifications and Acceptable Means of Compliance for Large Aeroplanes CS-25 (ED Decision 2012/008/R) is available on EASA website.

Provision of a baby bassinet is a cabin service provided by an airline to a parent travelling with a baby for the purpose of relieving the parent from holding the lap-held baby for a long period of time, especially on long-haul and ultra-long-haul flights.

Baby bassinets are included in the certification process of the aircraft in which they will be installed. They are not certified as separate devices, therefore an aircraft may not have a baby bassinet at all. The choice is up to the airline. The airline may choose to have a permanently installed ‘baby bed’ on its aircraft and its use during taxi, take-off, landing and turbulence will be described in the attached placards.

If baby bassinets are available on board, their number in the cabin depends on the cabin arrangement of the aircraft and locations where the bassinets can be safely attached/positioned. The number of baby bassinets at one location, usually at a bulkhead, depends on the available space, the weight the bulkhead can hold and the number of oxygen masks for the adults and babies located in that individual row.

Baby bassinet is not a child restraint device. Baby bassinets are not certified for taxi, take-off, landing and turbulent weather conditions. They may swing up and down and are not stable during turbulence, therefore the baby must be removed from the baby bassinet during turbulence and secured as instructed by your cabin crew members.

Airlines carrying baby bassinets on board may have varying policies on their use, therefore it is necessary to check the airline’s website or get in contact with the airline. The International Air Transport Association (IATA) may also be able to provide more information.

Certification placarding requirements
Placards advising on the stowage of baby bassinets during taxi, take-off, landing and turbulence are required either at the location where baby bassinets will be fixed to the aircraft structure (e.g. bulkhead) or a clearly visible instruction advising on the same must be placed on the baby bassinet itself.

The placarding requirements are related to the general certification requirements on placarding and intended function in accordance with Certifications Specifications and Acceptable Means of Compliance for Large Aeroplanes CS-25 (ED Decision 2012/008/R) and the marking requirements as specified in the approval of the equipment. For any questions on certification matters, please contact the EASA Certification directorate.

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Use of Child Seats on Board

Can I use a child seat on board for my baby/child? What about a rear-facing child seat?

EASA cares for the safe transport of babies and children by air and encourages the use of child seats on board an aircraft.
Having a child seat on board an aircraft requires an assessment of several aspects, such as the aircraft seat itself, if the aircraft seat is forward-facing or rear-facing, how the child seat can be safely secured on the aircraft seat, the distance between seat rows where the child seat is intended to be placed, etc. Practically all child seats allowed on board are those that have been tested and certified for the use in cars. There may be limitations for their use in cars and there are also limitations for their use in an aircraft cabin. Depending on the specifics of the child seat, but also on the specifics of the aircraft seats and of the aircraft cabin arrangement, the operator decides which child seats are accepted on board its aircraft and which ones cannot be accepted due to safety reasons.

Rear-facing child seats are recommended for the use in cars for babies and children up until the age of 4. The use of a rear-facing (also referred to as ‘aft-facing’) child seat on board an aircraft may however be limited due to the distance between passenger seat rows (so-called ‘seat pitch’). Airlines are free to order from an aircraft manufacturer an aircraft with a cabin arrangement of their choice (including the distance between seat rows) provided it is compliant with the existing aircraft certification rules. Each cabin arrangement must be approved by EASA and must comply with the applicable safety standards including emergency evacuation. EU legislation however does not specify a prescriptive figure related to the minimum distance between seats (i.e. seat rows), aircraft designers comply with the standards using a range of biometrics.

It is the operator’s responsibility to establish procedures for its operation which are subject to the approval or acceptance by the National Aviation Authority of that EU Member State. Please, contact your airline for information on types of child seats and their use on board the airline’s aircraft. You may also wish to visit the EASA webpage ‘Travelling with children’.

Extract from the EU rules on air operations related to the acceptance of child seats on board:

CAT.IDE.A.205 Seats, seat safety belts, restraint systems and child restraint devices

(a) Aeroplanes shall be equipped with:

(1) a seat or berth for each person on board who is aged 24 months or more;

(2) a seat belt on each passenger seat and restraining belts for each berth except as specified in (3);

(3) a seat belt with upper torso restraint system on each passenger seat and restraining belts on each berth in the case of aeroplanes with an MCTOM of 5 700 kg or less and with an MOPSC of nine or less, having an individual CofA first issued on or after 8 April 2015;

(4) a child restraint device (CRD) for each person on board younger than 24 months;

(5) …

AMC1 CAT.IDE.A.205 Seats, seat safety belts, restraint systems and child restraint devices
CHILD RESTRAINT DEVICES (CRDs)

(a) A CRD is considered to be acceptable if:

(1) it is a ‘supplementary loop belt’ manufactured with the same techniques and the same materials as the approved safety belts; or

(2) it complies with (b).

(b) Provided the CRD can be installed properly on the respective aircraft seat, the following CRDs are considered acceptable:

(1) CRDs approved for use in aircraft according to the European Technical Standard Order ETSO-C100c on Aviation Child Safety Device (ACSD);

(2) CRDs approved by EASA through a Type Certificate or Supplemental Type Certificate;

(3) Child seats approved for use in motor vehicles on the basis of the technical standard specified in point (i) below. The child seat must be also approved for use in aircraft on the basis of the technical standard specified in either point

(ii) or point (iii):

(i) UN Standard ECE R44-04 (or 03), or ECE R129 bearing the respective ‘ECE R’ label; and

(ii) German ‘Qualification Procedure for Child Restraint Systems for Use in Aircraft’ (TÜV/958-01/2001) bearing the label ‘For Use in Aircraft’; or

(iii) Other technical standard acceptable to the competent authority. The child seat should hold a qualification sign that it can be used in aircraft.

(4) Child seats approved for use in motor vehicles and aircraft according to Canadian CMVSS 213/213.1 bearing the respective label;

(5) Child seats approved for use in motor vehicles and aircraft according to US FMVSS No 213 and bearing one or two labels displaying the following two sentences:

(i) ‘THIS CHILD RESTRAINT SYSTEM CONFORMS TO ALL APPLICABLE FEDERAL MOTOR VEHICLE SAFETY STANDARDS’; and

(ii) in red letters ‘THIS RESTRAINT IS CERTIFIED FOR USE IN MOTOR VEHICLES AND AIRCRAFT’;

(6) Child seats approved for use in motor vehicles and aircraft according to Australia/New Zealand’s technical standard AS/NZS 1754:2013 bearing the green part on the label displaying ‘For Use in Aircraft’; and

(7) CRDs manufactured and tested according to other technical standards equivalent to those listed above. The devices should be marked with an associated qualification sign, which shows the name of the qualification organisation and a specific identification number, related to the associated qualification project. The qualifying organisation should be a competent and independent organisation that is acceptable to the competent authority.

(1) Forward-facing child seats may be installed on both forward-and rearward-facing passenger seats, but only when fitted in the same direction as the passenger seat on which they are positioned. Rearward-facing child seats should only be installed on forward-facing passenger seats. A child seat should not be installed within the radius of action of an airbag unless it is obvious that the airbag is de-activated or it can be demonstrated that there is no negative impact from the airbag.

(2) An infant/child in a CRD should be located in the vicinity of a floor level exit.

(3) An infant/child in a CRD should not hinder evacuation for any passenger.

(4) An infant/child in a CRD should neither be located in the row (where rows are existing) leading to an emergency exit nor located in a row immediately forward or aft of an emergency exit. A window passenger seat is the preferred location. An aisle passenger seat or a cross aisle passenger seat that forms part of the evacuation route to exits is not recommended. Other locations may be acceptable provided the access of neighbour passengers to the nearest aisle is not obstructed by the CRD.

(5) In general, only one CRD per row segment is recommended. More than one CRD per row segment is allowed if the infants/children are from the same family or travelling group provided the infants/children are accompanied by a responsible adult sitting next to them in the same row segment.

(6) A row segment is one or more seats side-by-side separated from the next row segment by an aisle.

(d) Installation

(1) CRDs tested and approved for use in aircraft should only be installed on a suitable passenger seat by the method shown in the manufacturer’s instructions provided with each CRD and with the type of connecting device they are approved for the installation in aircraft. CRDs designed to be installed only by means of rigid bar lower anchorages (ISOFIX or equivalent) should only be used on passenger seats equipped with such connecting devices and should not be secured by passenger seat lap belt.

(2) All safety and installation instructions should be followed carefully by the responsible adult accompanying the infant/child. Operators should prohibit the use of a CRD not installed on the passenger seat according to the manufacturer's instructions or not approved for use in aircraft.

(3) If a forward-facing child seat with a rigid backrest is to be fastened by a seat lap belt, the restraint device should be fastened when the backrest of the passenger seat on which it rests is in a reclined position. Thereafter, the backrest is to be positioned upright. This procedure ensures better tightening of the child seat on the aircraft seat if the aircraft seat is reclinable.

(4) The buckle of the adult safety belt must be easily accessible for both opening and closing, and must be in line with the seat belt halves (not canted) after tightening.

(5) Forward-facing restraint devices with an integral harness must not be installed such that the adult safety belt is secured over the infant.

(e) Operation

(1) Each CRD should remain secured to a passenger seat during all phases of flight unless it is properly stowed when not in use.

(2) Where a child seat is adjustable in recline, it must be in an upright position for all occasions when passenger restraint devices are required.

Extract from the International Civil Aviation Organisation (ICAO) guidance on the approval and use of child restraint systems (ICAO Document 10049):

2.4.3 The seat pitch or the available space between two rows of seats may also be an issue and particularly significant for aft-facing CRS as they are further reclined and take up more horizontal space. The inability to be effectively installed using existing aircraft seat belts may also render motor vehicle CRS ineffective on board. The location of anchor points can also be problematic. This includes the location of the aircraft seat belt attachment to the aircraft seat, as a CRS must translate forward until the belt path angle allows for belt tension forces to restrain the device.

Note: CRS stands for ‘child restraint system’ and means the same as ‘child restraint device’.

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Passenger safety briefing

Is there any requirement on what language(s) should be used for information provided to passengers via safety briefings and announcements?

Reference: Regulation (EU) No 965/2012 Air Operations, Annex III: Part-ORO is available on EASA website. ICAO Doc 10086 Manual on information and instructions for passenger safety is available on ICAO website.

Regulation (EU) No 965/2012 mandates the operator to ensure that briefings and demonstrations related to safety are provided to passengers in a form that facilitates the application of the procedures applicable in case of an emergency and that passengers are provided with a safety briefing card on which picture type-instructions indicate the operation of emergency equipment and exits likely to be used by passengers. It is therefore the operator’s responsibility to choose the languages to be used on its flights, which may vary depending on the destination or a known passenger profile. It is indeed difficult, if not impossible, to accommodate every ‘required’ language on board as this differs on daily basis from a flight to flight. For example, a German airline has a flight departing from Frankfurt to Rome and it is assumed that the most required languages on this flight will be German and Italian. The passenger profile may, however, be such that these languages are not ‘desired’ on this flight as passengers do not necessarily speak or understand any of the two languages (passengers may be e.g. Irish, Canadian, Russian, Chinese, Iranian, Egyptian, Pakistani, Latvian, Finnish, Croatian, Hungarian, Bulgarian, Czech, Slovak, etc., or there is a large group of e.g. Japanese tourists). It is therefore a practice of some operators to employ ‘language speakers’, i.e. cabin crew members speaking certain languages, who mainly operate their language-desired route(s). The aircraft may also have an option of a multi-language pre-recorded set of public announcements, the operator may choose this feature when modifying the cabin systems on its aircraft configuration.

ICAO Doc 10086 recommends that information provided to passengers via safety briefings, announcements and safety demonstrations should be transmitted in the language of the operator and in English to promote appropriate communication with passengers. Further, that in order to cover the largest percentage of passengers on board on international flights, the operator should consider the use of English and the use of the official language of the State of departure and destination. In addition, the operator should consider the language(s) of the passengers on board and assign language-qualified cabin crew members or interpreters on board the aircraft, on specific routes. The operator should verify that emergency exit-row occupants comprehend the language spoken by the crew.

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Part-SPA

SPA.HEMS.110 Equipment requirements for HEMS operations specifies: "The installation of all helicopter dedicated medical equipment and any subsequent modifications and, where appropriate, its operation shall be approved in accordance with Regulation (EC) No 1702/2003". Does it mean that even a defibrillator or an oxylog has to be approved in accordance with Regulation (EC) 1702/2003 or (EU) 748/2012? Or does it mean that only the fix installed medical equipment, such as a stretcher or a fix provision, has to be approved?

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Dangerous Goods

Is there a European regulation on dangerous goods training requirements or should each European country follow its own national regulations?

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Q2: What are the rules concerning the carriage of portable air concentrators (POC) on board? Can they be used during the whole flight?

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Q1: What are the rules for passengers using bottled oxygen on board an aircraft?

[NOTE: Q1 and Q2 must be read together as they are closely related.]

Reference: Regulation (EU) No 965/2012 on Air Operations; Regulation (EC) No 1107/2006 on the right of disabled persons and persons with reduced mobility when travelling by air

Article 10 of Regulation (EC) No 1107/2006 establishes the rights of disabled persons and persons with reduced mobility when travelling by air. The Regulation also stipulates that air operators should provide assistance, including transportation of medical equipment subject to dangerous goods legislation. Article 4(3) of this Regulation requires an air carrier or its agent to make publicly available the safety requirements and relevant information on restrictions. Annex II to the Regulation stipulates that the relevant legislation on dangerous goods can be invoked to limit the transport of mobility equipment. For more information on Regulation 1107/2006, please refer to the Commission's interpretative guidelines on this regulation from 11.06.2012, which has been published on the Commission's website and can be accessed here.

Regulation (EU) No 965/2012 of 5 October 2012 on Air Operations (Air OPS Regulation) refers to Annex 18 of the Chicago Convention and the Technical Instructions for the Safe Transport of Dangerous Goods by air when relating to their carriage on board. For safety reasons, oxygen/air cylinders or bottles are considered dangerous goods and fall under Annex 18 of the Chicago Convention; therefore, the provisions under Part 8 of the ICAO Technical Instructions must be applied to passengers who intend to carry these items with them on board. Oxygen/air cylinders for medical use of no more than 5 kg gross weight and never containing liquid oxygen are allowed in checked and carry-on baggage or on the person, with approval of the operator. In addition, the operator must provide the pilot-in-command with written information on their number and location on board. The valves and regulators of oxygen bottles must be protected from damage which could cause inadvertent release of the contents. Under the ICAO Technical Instructions, spare oxygen cylinders of a similar size are also allowed to ensure an adequate supply for the duration of the journey. The operator's Operations Manual, which has been approved by the National Authority, will contain procedures on the use of oxygen bottles.

Nevertheless, for safety reasons, national authorities may decide to prohibit all oxygen bottles, irrespective of their size, from being carried on board by passengers. Where the national authorities allow oxygen bottles of less than 5 kg to be taken on board, it is still left to the discretion of the operator to accept them, also due to safety reasons (oxygen is highly flammable and it cannot be guaranteed that the bottles/valves have been maintained properly).
If passengers have special needs, they should request more information from the airline at the time of booking.

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Which operators have to establish and maintain dangerous goods training programmes? Which training programmes should be approved by the authority?

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AMC1 ORO.GEN.200(b) ‘Management system. Size, nature and complexity of the activity ’ provides criteria to determine if an operator belongs to the group of complex organisations or the one of non-complex organisations. These criteria are based on the assessment of the size, nature and complexity of the operator’s activity.

The idea behind this AMC is to provide some basic criteria for an organisation (an operator) to establish which AMCs on management system they should follow — the more ‘comprehensive’ ones for complex organisations, or those including some specific ‘alleviations’ for the non-complex ones.

It is important to note that the assessment of organisational complexity is not only a function of size, but it also needs to consider the specific activities, the operating environment, the scope, the variety of different aircraft types operated, the contracted activities, etc. Therefore, the AMC includes some specific risk criteria.

The fact that this AMC is included in Part-ORO indicates that it is the operator’s responsibility to determine the right ‘layout’ of their management system. The competent authority will need to validate this determination during the oversight activities, and it may challenge the operator on the option retained (complex or non-complex).

At the same time, AMC1 ORO.GEN.200(b) does not include any overly detailed complexity criteria. This is because it is impossible to address all cases and, more importantly, it is not the intent that the AMC be used as a substitute for the operator’s own risk assessment.

The main ‘alleviations’ for a non-complex operator are the following:

The operator may use simple procedures and tools for its safety risk management process (e.g. checklists), and safety performance monitoring and measurement (no need to perform extensive safety studies, surveys, etc.).
The accountable manager or a person with an operational role in the organisation may fulfil the role of safety manager.
The organisation does not need to have a safety review board.
The accountable manager may also be the compliance-monitoring manager if he or she has demonstrated to have the required competence and that the independence of the internal audits is maintained.
Simple checklists may be used to document compliance monitoring audits and inspections.

Before the operator decides which AMCs to follow, it should demonstrate proper understanding of the risks entailed by its activities. Upon initial implementation of the EASA management system framework, the organisation will normally start describing and analysing its activity and processes, to determine not only how best to implement the management system framework, but also where to focus the risk management efforts. Not investing in this step will lead to inefficient/costly management system implementation and require subsequent rework.

Such system description and related analysis will be an effective means for identifying hazards proactively. It will also create a baseline for the management of changes and will allow identifying safety performance requirements for safety relevant processes, as well as related performance indicators and controls in order to manage the defined performance goals.

NCC.GEN.100 specifies the following: “The competent authority shall be the authority designated by the Member State in which the operator has its principal place of business or is residing”.
This means that the State of the Operator (SoO) designates the competent authority for NCC operators. Here are some examples:

For a European NCC operator with aircraft registered in a Member State, the Competent Authority is designated by the State of the Operator.
For a European NCC operator with third-country registered aircraft, the Competent Authority is designated by the State of the Operator. These operators may also have to comply with rules of the third-country State of Registry (SoR) if this State has not delegated its responsibilities to the European State of the Operator.
For a third-country NCC operator having its principal place of business in a third country and performing operations with aircraft registered in a Member State, the Competent Authority is designated by the State of the Operator (the third country SoO). However, these operators may also have to comply with rules of the EU Member State (State of Registry) related to the aircraft if the State of Registry has not delegated its responsibilities to the State of the Operator.

For cases under (2) and (3), the State of Registry and the State of the Operator need to coordinate their safety and security oversight actions in accordance with ICAO SARPs (3.4.2.1.2 of ICAO Annex 6 Part II).

To avoid interferences with the responsibility of a third-country State of Registry for specific approvals, Part-SPA SPA.GEN.100 specifies that the European competent authority shall not issue operational approvals when they are required by Annex 6 and issued by the third-country State of Registry.

EASA has published a draft Guidance Material (GM) related to this topic, in order to make it easier for declared operators (NCC and SPO) to determine which their competent authority is. The GM can be found in the draft AMC&GM related to Opinion 04/2017, published for information 'draft GM proposed to Annex I Definitions'.

A good starting point would be to describe your regular operation, the daily business. The description of your operation will give direction to your organisation’s effective SMS and will become its foundation.

This description should simply be a checklist containing the day-to-day activities, as it provides the understanding necessary to identify and manage the risks associated with the operation.

The analysis of your daily operation should consider the following aspects (this list is not exhaustive):

What is the frequency of your flights?
What aircraft type(s) do you have in your fleet?
What are your departure & destination points?
What is specific to the aerodromes you use?
Which are the routes on which you fly – more or less the same routes or very different routes?
Do you carry passengers?
What type of operation do you perform on those routes? Be as specific as you can.
Do you have a system that helps you prepare your flight?
How do you plan and calculate the necessary fuel supply?
Do you have any specific approvals (e.g., LVO, PBN, etc.)?
Are your pilots’ training and qualifications compliant with the requirements? How about the other employees involved in operation?
Are the operational procedures and any flight documents current and available to all the personnel involved in operation?
How do you ensure that the necessary information is communicated to the right persons involved in operation?
How do you ensure aircraft maintenance?
What do you do if any of the elements above changes for one reason or another? Are you prepared to cope with that change and minimise its effects in your daily operation? How do you deal with such changes?
Make sure you include the aspect of disruptive changes in your analysis.
Have you set up the minimum levels of acceptance to which every key operational activity (e.g. scheduling, planning, flight execution, fuel consumption, training, aircraft maintenance) can go? In other words, have you set up your performance expectations?

The last two questions will lead to the second step in building your SMS:

What could be the main potential risks associated to each of the elements above – what could go wrong with these daily variables?

Identifying the key elements of risk in this day-to-day operation will help you to spot more easily the strengths and weaknesses in your regular business, the errors, as well as the good practices.

The third step is then to choose/apply adequate mitigation measures to reduce the risks inherent to your daily operation:

Make a list of solutions to reduce each risk to an acceptable level. Consider to use the Risk register checklist proposed in GM3 ORO.GEN.200(a)(3) for your safety risk management/assessment.

A fourth step is to assess whether the mitigation measures that you have prepared are effective and help you to achieve the required level of safety.

Keep evidence of any occurrence, identify their cause, and see if they are repetitive and if they have anything in common.
Find ways to prevent them from reoccurring by addressing the “root cause”.
Check how well your solutions helped in preventing the reoccurrence of that event.

A fifth step ensures that the whole process becomes cyclic, and that you learn from your previous experience in order to make your operation safer and more efficient.

Run this check once a year or after an event or change in the aspects mentioned above.

Does this scheme address your needs and help you to have a safe operation?

According to AMC1 SPO.GEN.140(a)(3) a permit to fly may (PtF) be used in SPO operations, if issued in accordance with the applicable airworthiness requirements and subject to compliance with the flight conditions established by the competent authority.

The applicable airworthiness requirements are those contained in Commission Regulation (EU) No 748/2012 (Part-21 thereof). Part-21 contains a list of purposes for which a PtF may be issued under certain conditions. For example, a mission for air racing may be possible with PtF. Please check with your competent authority if the purpose of the SPO mission complies with that list and those conditions.

For non-commercial specialised operations falling under Part-NCO, NCO.GEN.135 (a) (3) requires the original certificate of airworthiness (CofA) be carried on each flight.

According to AMC1 NCO.GEN.135 (a) (3) a PtF may be used in NCO operations, if issued in accordance with the applicable airworthiness requirements and subject to compliance with the flight conditions established by the competent authority.

The applicable airworthiness requirements are those contained in Part-21. Part-21 contains a list of purposes for which a PtF may be issued under certain conditions. For example, a non-commercial flying activity on individual non-complex aircraft or types for which a certificate of airworthiness or restricted certificate of airworthiness is not appropriate (mainly, but not limited to, the so-called ‘orphan’ aircraft) may be possible with PtF. Please check with your competent authority if the purpose of the SPO mission complies with that list and those conditions.

Special Categories of Passengers (SCPs)

Who is an SCP?

References: Regulation (EC) No 1107/2006 is available on EUR-Lex website. Regulation (EU) No 965/2012 and Regulation (EU) 2018/1139 and the study EASA 2008.C.25 are available on EASA website.

SCPs are passengers who, when carried on a flight, require special conditions, assistance and/or devices and their situation needs appropriate attention and adaptation to their particular needs. These passengers shall not be allocated, nor occupy, seats that permit direct access to emergency exits or where their presence could impede crew members in their duties, obstruct access to emergency equipment or impede evacuation of the aircraft.

Under the EU law, aircraft operators are ultimately responsible for the safe operation of the aircraft and for the safety of passengers on board. Regulation (EU) No 965/2012 on air operations mandates the operator (airline) to establish procedures for its air operation. The operator’s procedures, and the operator’s activities overall, are under the oversight of the Competent Authority (CA) of the individual EU Member State. The CA has the necessary powers and allocated responsibilities for the certification and oversight of persons and organisations subject to Regulation (EU) 2018/1139 and its implementing rules.

The EU rule on SCPs states the following:

The rule is complemented by Acceptable Means of Compliance (AMC) and Guidance Material (GM) which address aspects such as the factors the operator should take into account when establishing procedures for carriage of SCPs, information provided to SCPs, conditions for safe carriage of unaccompanied children, a passenger capable of assisting in case of an emergency, seating allocation, etc. The EU provisions are available on EASA website (the link ‘Easy Access Rules for Air Operations’ contains the rule and the AMCs and GMs in one document):
https://www.easa.europa.eu/regulations#regulations-air-operations

The rules for air operations on SCPs have been developed under the EASA rulemaking tasks RMT.0269/0270 involving a rulemaking group. The track of this rulemaking activity is available on EASA website:

Terms of Reference (ToR) MDM.072 (a) & (b) (RMT.0269 & RMT.0270):
https://www.easa.europa.eu/document-library/terms-of-reference-and-group-compositions/tor-mdm072-b-rmt0269-rmt0270

Notice of Proposed Amendment NPA 2014-01
https://www.easa.europa.eu/document-library/rulemaking-subjects/carriage-special-categories-passengers-scps

Comment Response Document CRD 2014-01
https://www.easa.europa.eu/document-library/comment-response-documents/crd-2014-01

ED Decision 2016/004/R
https://www.easa.europa.eu/document-library/agency-decisions/ed-decision-2016004r

Study on Carriage by Air of Special Categories of Passengers (SCPs), EASA 2008.C.25:
https://www.easa.europa.eu/document-library/research-projects/easa2008c25

Additional information
Regulation (EU) 2018/1139 on common rules in the field of civil aviation and establishing a European Union Aviation Safety Agency specifies the mandate entrusted to EASA by the European Parliament and by the Council:
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32018R1139

Regulation (EC) No 1107/2006 of the European Parliament and of the Council contains the European provisions on rights of disabled persons and persons with reduced mobility (PRMs) when travelling by air: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=LEGISSUM:l24132 . Questions on this regulation should be addressed to the European Commission.

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I am tall or have other circumstances. Do I belong to the group of SCPs?

References: Regulation (EC) No 1107/2006 is available on EUR-Lex website. Regulation (EU) No 965/2012 and the study EASA 2008.C.25 are available on EASA website.

Regulation (EC) No 1107/2006 of the European Parliament and of the Council on rights of disabled persons and persons with reduced mobility (PRMs) when travelling by air does not include the height of an individual in the definition of ‘disability or a person with reduced mobility’. Hence, the EU rules on air operations - Regulation (EU) No 965/2012 - do not include a height of an individual (i.e. a tall passenger) in the ‘special categories of passengers (SCPs)’.

Air operators are free to order from an aircraft manufacturer an aircraft cabin/seat configuration they wish, provided that such cabin/seat configuration meets the certification safety requirements. The space between seat rows (so-called ‘seat-pitch’) is a matter of aircraft certification process*. *Questions on aircraft certification matters should be addressed to EASA Certification Directorate.

EASA has conducted a study on Carriage by air of special categories of passengers, reference EASA 2008.C.25, which, amongst others, concludes that aircraft designers must take into account the increasing percentage of tall passengers. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32018R1139

There may be passengers who do not fall into the category specified by the EU regulations on PRMs and SCPs referenced above, however they may have certain individual circumstances where intervention of the air operator or the Competent Authority may be beneficial or required. Most airlines offer various forms of assistance to passengers with certain requirements. For example, persons suffering from certain specific allergies (not necessarily food-related) are not considered disabled and do not fall into the SCP category either. However, passengers with any such circumstances may contact the operator, or the Competent Authority, to seek a solution prior to their travel.

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What happens following the submission of the ‘one-off notification’ accompanied with the provided application form and supporting documents?

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		Complex motor-powered aircraft	Other than complex motor-powered aircraft
Commercial DTO	Applicable requirement	M.A.201(f) is applicable	M.A.201(h) or, for aircraft specified in Article 3(2), ML.A.201(e) are applicable
	Continuing airworthiness management	CAMO is required	CAO (with continuing airworthiness management privilege) or CAMO is required
	Maintenance	Part-145 organisation is required	CAO (with maintenance privilege) or Part-145 or Part-M Subpart F organisation is required
Non-Commercial DTO	Applicable requirement	M.A.201(g) is applicable	M.A.201(i) or, for aircraft specified in Article 3(2), ML.A.201(f) are applicable
	Continuing airworthiness management	CAMO is required	CAMO is not required CAO (with continuing airworthiness management privilege) is not required
	Maintenance	Part-145 organisation is required	With the exception of complex maintenance tasks under Part-M: CAO (with maintenance privilege) is not required Part-145 organisation not required Part-M Subpart F organisation is not required

Commercial operations	Commercial air transport (CAT) operations	Technical rules: Part-CAT
		Operator rules: Part-ORO
	Specialised operations (aerial work)	Technical rules: Part-SPO
		Operator rules: Part-ORO
Non-commercial operations	Non-commercial operations other than SPO (e.g. business/corporate flights, leisure flights, private flights, training flights)	With CMPA:	Technical rules: Part-NCC Operator rules: Part-ORO
		With Ot-CMPA:	Technical rules: Part-NCO
	Specialised operations (aerial work)	With CMPA:	Technical rules: Part-SPO Operator rules: Part-ORO
		With Ot-CMPA	Technical rules: Part-NCO

What is the content and purpose of the EASA type rating and licence endorsement lists?

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Why do the EASA type rating and licence endorsement lists not contain references to the latest applicable version of an OSD FC document?

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Are ODR tables available as part of the operational suitability data (OSD) for flight crew (FC) document?

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When should changes to OSD FC provisions be implemented by users to take into account any revised mandatory elements included in a revision?

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What is the status of non-mandatory items in the OSD FC? How should users proceed if deviating from non-mandatory items in the OSD FC?

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What aspects should be considered when substituting a training level or device described in the OSD FC by another training level or device?

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How can I get access to OSD FC documents?

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What is the difference between the terms FCL (Flight Crew Licensing) and Aircrew?

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Following the introduction of a new variant to an existing type rating, how do pilots attain the privileges to operate the new variant?

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How should the new class and type rating list for aeroplanes which is published on the Agency’s website be understood?

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How can a third country (non-EU) licence be converted into a Part-FCL licence?

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Could the European Central Question Bank be published?

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Is UPRT also be mandatory for the LAPL and the PPL?

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My cabin crew qualification document was issued in a country that is not a member of the European Union and is not an EASA Member State either. Is my cabin crew qualification document recognised in the European Union?

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Is there any requirement on cabin crew member(s) communication with passengers in a certain language?

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Do cabin crew members have to be able to speak English to obtain their Cabin Crew Attestation?

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Do I have to undergo Aircraft type specific training and operator conversion training with every new operator I join if I am already qualified on that aircraft type?

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Can a cabin crew training organisation (CCTO) provide Aircraft type specific training and operator conversion training?

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Do the evacuation procedures with a reduced number of required cabin crew during ground operations or in unforeseen circumstances require prior endorsement?

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Determination of the minimum required number of cabin crew on an aircraft

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What credit can I get as regards Subject 090 Communications for my IR, CPL or ATPL(H)/VFR?

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