Regulations

Aircrew

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

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

Two separate EASA type rating and licence endorsement lists - flight crew are published by EASA (one for helicopters and one for all other aircraft): Type Ratings and Licence endorsement lists.

These lists constitute the class and type of aircraft categorisations in accordance with definitions of category of aircraft, class of aeroplane, and type of aircraft and paragraph FCL.700 and GM1 FCL.700 of Annex I (Part-FCL) to Commission Regulation (EU) No 1178/2011.  

The lists also indicates if operational suitability data (OSD) for flight crew are available. EASA type certificate data sheets (TCDSs) and the list of EASA supplemental type certificates contain further references to OSD. Complete current OSD information is held by the relevant type certificate (TC) or supplemental type certificate (STC) holder.

Furthermore, the lists provide aircraft-specific references relevant to flight crew qualifications and air operations, including references to (non-OSD) documents, such as (J)OEB reports or Operational Evaluation Guidance Material (OE GM).

Explanatory notes for these lists are found at the same website location.

View

Was this helpful?

Vote up  6
Vote down  2

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

The EASA type rating and licence endorsement lists indicate whether an OSD FC document for a relevant aircraft exists. OSD FC documents are certification documents which are held and maintained by TC/STC Holder and are subject to Annex I to Commission Regulation No 748/2012 (Part-21) provisions. Consequently, changes to OSD are handled in accordance with Part-21 procedures in the same way that e.g. changes to aeroplane flight manual (AFM’s) are dealt with. This includes the principle of delegation of privileges to DOAs based on which minor changes to OSD FC are approved under DOA privileges.

The responsibility of tracking the OSD FC document version resides therefore with the TC/STC holder and referencing that in the TR and licence endorsement list could potentially generate inconsistencies.

Users should consider establishing a process to ensure the regular receipt of OSD FC updates, similarly to what might exist for holding current AFM and quick reference handbook (QRH) documents.

View

Was this helpful?

Vote up  1
Vote down  5

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

ODR tables which have been established as part of an OSD FC operational evaluation, are part of the OSD FC data, approved under the type certificate (TC)/ supplemental type certificate (STC) and owned by the TC/STC holder. These ODR tables are original equipment manufacturer OEM generic and must be customized for use by operators to their specific aircraft configurations.

Such ODR tables should therefore be requested directly from the TC/STC holder which has an obligation according to Part-21 to make OSD FC documents available to users.

View

Was this helpful?

Vote up  3
Vote down  3

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

Article 9a of Commission Regulation No 1178/2011 (amended by Commission Regulation No 70/2014) contains a 2 year transition period for the implementation after initial publication of OSD FC report. This allows training providers, such as ATOs and operators time to adapt their training programmes and provide additional training if needed.

Pilot training courses which were approved before the approval of the OSD FC data should contain the mandatory elements not later than 18 December 2017 or within 2 years after the OSD FC was approved, whichever is later.

Implementation of changes to the OSD FC into existing approved training courses should be implemented within a reasonable timeframe following the OSD change. This timeframe is not clearly defined within the aircrew regulation, however a timeframe of 3 months (or 90 days as under the air ops requirements for an MEL) is considered reasonable. 

View

Was this helpful?

Vote up  2
Vote down  1

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?

The data contained in OSD FC documents are identified as either ‘mandatory’ or ‘non-mandatory’ elements. While mandatory elements have the status of a rule, non-mandatory elements have the status of Acceptable Means of Compliance (AMC). 

In order to provide some flexibility to users, non-mandatory elements typically address such items as training devices, training duration, previous experience, or currency. In line with the general principles for AMCs, these elements are non-binding provisions established as a means of compliance with the Aircrew Requirements.

Users may choose Alternative Means of Compliance (AltMoC) to use alternatives to the OSD-FC non-mandatory parts by following the dedicated process for AltMoCs described in the implementing rules for aircrew licensing and air operations. Further details on the AltMoC process can be found on EASA's website.

View

Was this helpful?

Vote up  4
Vote down  1

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

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.

View

Was this helpful?

Vote up  4
Vote down  0

How can I get access to OSD FC documents?

Contrary to Operational Evaluation Board (OEB) reports which were owned and published by EASA, OSD documents are certification documents which are held by the TC/STC Holder within the framework of Annex I to Commission Regulation No 748/2012 (Part-21). 

Paragraph 21.A.62 of Part-21 establishes requirements for the owner of the data (type certificate (TC)/supplemental type certificate (STC) holder) on making these OSD data available. It reads as follows:

21.A.62 Availability of operational suitability data
The holder of the type-certificate or restricted type-certificate shall make available: 

(a) at least one set of complete operational suitability data prepared in accordance with the applicable operational suitability certification basis, to all known EU operators of the aircraft, before the operational suitability data must be used by a training organisation or an EU operator; and 

(b) any change to the operational suitability data to all known EU operators of the aircraft; and 

(c) on request, the relevant data referred to in points (a) and (b) above, to: 

1. the competent authority responsible for verifying conformity with one or more elements of this set of operational suitability data; and 
2. any person required to comply with one or more elements of this set of operational suitability data.

Consequently, users should request OSD data from the relevant owner, when required. 

To assist users in contacting the relevant owner of the document, EASA provides some information on its website for OSD, in particular an OSD contact list based on feedback from manufacturers. 
 

View

Was this helpful?

Vote up  10
Vote down  1

Licensing

How can a national pilot licence be converted into a Part-FCL licence?

Existing national pilots licences will be converted in accordance with Article 4 of Commission Regulation (EU) No 1178/2011 on Aircrew and its amending Commission Regulation (EU) No 290/2012.

JAR-compliant licences issued or recognised by the Member State before the applicability of Commission Regulation (EU) No 1178/2011 on Aircrew shall be deemed to have been issued in accordance with this Regulation, and shall be replaced with a Part-FCL licence by 8 April 2018 at the latest.

Non-JAR-compliant licences, including any associated ratings, certificates, authorisations and/or qualifications issued or recognised by the Member State before applicability of Commission Regulation (EU) No 1178/2011 on Aircrew shall be converted into Part-FCL licences by the Member State that issued the licence in accordance with the provisions of Annex II to that Regulation or the requirements laid down in a conversion report.

As stated in Commission Regulation (EU) No 1178/2011 on Aircrew, the application date was 8 April 2012, though flexibility was introduced via transition measures contained in Article 12 of Regulation (EU) No 1178/2011 on Aircrew and Article 1 paragraph (6) of Regulation (EU) No 290/2012.

View

Was this helpful?

Vote up  10
Vote down  6

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

Aircrew is the common term for "Flight Crew" and "Cabin Crew".
The new Implementing Rules cover both flight crew and cabin crew, and were published as Commission Regulation (EU) No 1178/2011 laying down technical requirements and administrative procedures related to civil aviation aircrew and its amending Commission Regulation (EU) No 290/2012.

Annex I to the above-mentioned Regulation on Aircrew contains Implementing Rules for Flight Crew (Part-FCL).

Annex V to this Regulation on Aircrew contains Implementing Rules for Cabin Crew (Part-CC).

View

Was this helpful?

Vote up  48
Vote down  5

Will a licence issued in accordance with JAR-FCL requirements still be valid once the new rules become applicable?

Commission Regulation (EU) No 1178/2011 on Aircrew contains transition measures to ensure that JAR-FCL licences issued by Member States in accordance with JAR-FCL requirements and procedures will be grandfathered.

This means that holders of JAR compliant pilots' licences can continue to exercise the privileges of their licences after Commission Regulation (EU) No 1178/2011 on Aircrew applies, without the need for any further administrative procedures, but these licences shall be replaced with Part-FCL licences by 8 April 2018 at the latest. Further information can be found in paragraph 3 of Article 1 of Commission Regulation (EU) No 290/2012 on Aircrew (which amends the date of 8 April 2017 as stated in paragraph 1 of Article 4 of Commission Regulation (EU) No 1178/2011).

Please note that Member States are not forced to replace valid JAR pilots' licences before the end of their validity period as these licences will be deemed to have been issued under the Part-FCL requirements.

View

Was this helpful?

Vote up  17
Vote down  9

Will a national licence that does not comply with JAR-FCL requirements still be valid once the new rules become applicable?

Once Commission Regulation (EU) No 1178/2011 on Aircrew becomes applicable in a certain Member State, it will no longer be possible to fly with a licence that does not comply with those requirements (except in the case of aircraft included in Annex II to Regulation (EC) No 216/2008, according to Article 4(5)). 
Consequently, a national licence will need to be converted into a Part-FCL licence. To deal with those licences issued by Member States in accordance with national rules deviating from JAR-FCL, transition measures have been established in Commission Regulation (EU) No 1178/2011 on Aircrew. These transition measures foresee a certain amount of time to convert the national licences into fully compliant Part-FCL licences.

As stated in Article 12 of Commission Regulation (EU) No 1178/2011 on Aircrew, the application date is 8 April 2012, though by way of derogation from this paragraph, Member States may decide not to apply the provisions of Annex I related to pilot licences of powered-lift aircraft, balloons, airships and sailplanes until 8 April 2015. 
Member States may also decide not to convert non-JAR-compliant aeroplane and helicopter licences that they have issued until 8 April 2014.

Non-JAR compliant national licences may be converted into Part-FCL licences by the competent authority as follows:

  • for aeroplanes and helicopters, in accordance with the requirements of Annex II to Commission Regulation (EU) No 1178/2011 on Aircrew ;
  • for other categories of aircraft, on the basis of a conversion report drawn up by the competent authority.
View

Was this helpful?

Vote up  6
Vote down  6

Could the Agency assist with interpreting the JAR-FCL requirements?

JAR-FCL was drafted to harmonise European regulations on flight crew licensing in order to facilitate mutual recognition of licences and ratings. However, the Joint Aviation Requirements (JAR) (see the JAA publications) have been implemented under national law and under the full responsibility of each Member State.

Therefore the Rulemaking Directorate is not in the position to interpret or make comments on JAR-FCL requirements. In addition, please note that the Agency cannot intervene in cases where the national JAR text deviates from the original.

The national aviation authorities are responsible for interpreting and implementing JAR-FCL requirements.
We therefore recommend that for assistance in interpreting the JAR-FCL requirements, the national aviation authorities should be contacted directly.

A list of the national aviation authorities can be found here.

View

Was this helpful?

Vote up  6
Vote down  8

Is it correct that there are new requirements for instrument ratings (IR) and provisions to allow cloud flying for sailplane pilots published in the Aircrew Regulation?

Yes, this is correct.

On 3 April 2014 Commission Regulation 245/2014 and Agency ED Decision 2014/022/R entered into force. This Regulation and associated AMC/GM include a new competency-based instrument rating (CB IR) and an en route instrument rating (EIR) for private (PPL(A)) and commercial pilot (CPL(A)) licence holders, and a sailplane cloud flying rating.

The new provisions establish a more accessible IR enabling more European General Aviation (GA) pilots to obtain such rating, thereby increasing safety by reducing the number of potential controlled flights into terrain (CFIT). Moreover, the proposed CB IR course will contain a reduced theoretical knowledge (TK) syllabus appropriately reflected by a different level of TK examinations and a reduced amount of instrument flight instruction time when compared with the existing IR courses. Furthermore, the EIR requires less training, but nevertheless consists of more comprehensive flight training when compared to the basic instrument flight module of the existing IR. As the EIR only provides en route IFR privileges, this rating serves as a stepping stone towards the IR through the proposed competency-based route. Both CB IR and EIR include provisions for crediting a certain amount of instrument flight time on aeroplanes outside of an ATO, such as instrument flight time under instruction, prior pilot-in-command (PIC) instrument flight time, including crediting provisions for third-country IR holders.

The cloud flying rating for sailplane pilots allows holders to enter clouds whilst taking into account the airspace structure, the required minima in different airspace categories, and the relevant Air Traffic Control (ATC) procedures.

View

Was this helpful?

Vote up  14
Vote down  11

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

  1. Licensing following the introduction of a new variant to an existing type rating.

    When a new variant of a type is introduced the existing type endorsement in the pilot licence may remain unchanged but valid for all variants as included in the ‘EASA Type Rating & License Endorsement List Flight Crew’ published on the Agency’s web page. The new endorsement should be added by the pilot’s competent authority at the next routine licensing action or at the request of the pilot in accordance with ARA.FCL.220 (a).
     

  2. Exercise of the licence privileges in the new variant.

    The pilot must receive differences training or familiarisation as appropriate in accordance with FCL.710. This would mean the pilot has to undergo a differences training course under the responsibility of a qualified instructor and have it confirmed with the instructor’s signature in the pilot’s logbook.
     

  3. Qualification of pilots, instructors and examiners for the new variant:

     

    1. Pilots holding a type rating intending to operate the new variant should receive differences training in accordance with FCL.710. This differences training is to be recorded in the pilot’s logbook and signed by a qualified instructor.
       
    2. Instructors holding instructor privileges as a TRI or SFI on the existing type intending to use their instructor privileges also on the new variant should qualify in accordance with either FCL.900(b) (special conditions for the introduction of a new type) or with (a) above (differences training on the new variant).
       
    3. Examiners holding examiner privileges as a TRE or SFE on the existing type intending to use their examiner privileges also on the new variant should qualify in accordance with either FCL.1000(b) (special conditions for the introduction of a new type) or with (a) and (b) above (differences training on the new variant and instructor privileges).
       
    4. Pilots, instructors and examiners without existing type privileges shall complete the full type rating course and follow the requirements of Part-FCL for instructor and examiner privileges on any variant in the type.
View

Was this helpful?

Vote up  15
Vote down  12

How can a national pilot licence be converted into an EASA pilot licence?

In accordance with Regulation (EC) No 216/2008 in the field of pilot licensing, the Agency is not authorised to issue pilot licences and therefore there will not be any EASA pilot licence in the future.

According to Annex I (Part-FCL) to Commission Regulation (EU) No 1178/2011 on Aircrew, the title of a new licence issued in accordance with this Annex is a Part-FCL licence.

National licences shall be converted into Part-FCL licences by the competent authority of the Member State that issued the national licence in accordance with Article 4 of Commission Regulation (EU) No 1178/2011 on Aircrew and its amending Commission Regulation (EU) No 290/2012.

Conclusion:
The competent authorities of Member States will convert and issue Part-FCL licences and not the Agency.

View

Was this helpful?

Vote up  37
Vote down  12

How should the new class and type rating list for aeroplanes which is published on the Agency’s website be understood ? (complex aircraft, SET class, PA 46, instructor qualification)

The new list intends to make it easier to find specific aeroplanes by putting them into alphabetical order and abandoning the former grouping into many different lists. The aeroplanes which belong to the group of single pilot high performance complex aeroplanes are identified as such.

  1. Information on the SET class:
    Those aeroplanes that belong to a specific group whilst they still require aeroplane specific training, testing and checking have a licence endorsement that specifies that they are in this group and the remarks column provides any information if an OSD report was established. (SET class with a validity of 2 years, FCL.740(a)).
    Nevertheless all members of the SET class rating group require a class rating specific for the aeroplane and those ratings have to be revalidated individually with the possibility of any credits that are mentioned in the OSD for the relevant aeroplane.
    There is no generic SET (land) or SET(sea) rating to be entered in a pilot licence.
     
  2. Information on PA 46:
    The piston engine variants of the PA 46 may now be treated as falling within the SEP(land) class but require a difference training on one of the PA 46 piston engine variants. For revalidation there is no class specific requirement the revalidation can be done by experience on any SEP plus a training flight on any SEP or any proficiency check or no experience and a proficiency check on any SEP.
    The SET PA 46 class rating can be obtained with an approved difference training course from the piston engine PA 46 or with a specific SET PA 46 class rating course both of which have to be done in an ATO on a SET PA 46. As it is a separate class rating the requirements of FCL.725 (a)(b)(c) apply and as it is an HPA also the relevant requirements for those aeroplanes apply.
     
  3. Information on instructor qualification for SET class:
    With the facts mentioned above the instructor requirements for a CRI or FI are to be considered class specific. Meaning PA 46 with piston engine will require an instructor qualification for SEP with difference training for the PA 46 piston engine. All SET class ratings to be covered as individual class ratings with individual instructor qualifications as indicated on the licence endorsement list.

The list will shortly undergo further editorial changes. The Agency tries to make the list more easily understandable and therefore has amended it and the explanatory note that comes with it.”

View

Was this helpful?

Vote up  18
Vote down  14

When will the new rules on pilot licensing be applicable?

The new Implementing Rules implementing the requirements set out in Regulation (EC) No 216/2008 in the field of pilot licensing were published as Commission Regulation (EU) No 1178/2011 on Aircrew in the Official Journal of the European Union on 25 November 2011.
In November 2011, the first four annexes to Commission Regulation (EU) No 1178/2011 on Aircrew were published:

  • Annex I - Part-FCL (flight crew licensing)
  • Annex II - Conditions for the conversion of existing national licences and ratings for aeroplanes and helicopters
  • Annex III - Conditions for the acceptance of licences issued by or on behalf of third countries
  • Annex IV - Part-MED (medical).

The remaining annexes were published in the Official Journal of the European Union on 5 April 2012 as Commission Regulation (EU) No 290/2012 amending Commission Regulation (EU) No 1178/2011 on Aircrew. These annexes are:

  • Annex V - Part-CC (cabin crew)
  • Annex VI - Part-ARA (authority requirements for aircrew)
  • Annex VII - Part-ORA (organisation requirements for aircrew)

As stated in Article 12 paragraph 1 of Commission Regulation (EU) No 1178/2011 on Aircrew, the application date was 8 April 2012, though by way of derogation from this paragraph in accordance with Article 1 paragraph (6) and Article 2 paragraph 2. (a) of Commission Regulation (EU) No 290/2012, Member States could decide not to apply the provisions of the aforementioned Annexes until 8 April 2013.
The amending Regulation introduced additional transition measures deferring the applicability of certain Implementing Rules to a later date. Therefore the exact date of applicability of each requirement depends on the transition measures introduced by the Member States. 
Until the date the new Implementing Rules apply, Member States national rules remain in force. 
The related Acceptable Means of Compliance and Guidance Material to:

View

Was this helpful?

Vote up  12
Vote down  19

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

Pilots licences issued by third countries will be accepted in accordance with Article 8 of Commission Regulation (EU) No 1178/2011 on Aircrew .

According to paragraph 1 of this Article 8, the Member State may accept a third country licence, and the associated medical certificate, in accordance with the provisions of Annex III to the Regulation.
For the issue of a Part-FCL licence, the holder of at least an equivalent third country licence issued in accordance with ICAO Annex 1 shall comply with all the relevant requirements of Annex I to the Regulation (Part-FCL), except that the requirements of course duration, number of lesson and specific training hours may be reduced.

As stated in Article 12 of Commission Regulation (EU) No 1178/2011 on Aircrew, the application date was 8 April 2012, though by way of derogation from this paragraph, Member States could decide not to apply the provisions of Annex I to pilots holding a licence and associated medical certificate issued by a third country involved in non-commercial flights until 8 April 2015.

The competent authority of the Member State to which an applicant applies will determine the conversion requirements, which can be reduced on the basis of a recommendation from an approved training organisation.

Therefore, the national aviation authority of the Member State where an applicant resides or wishes to work should be contacted for further information concerning the applicable acceptance requirements.

To find a list of the national aviation authorities, please follow this link.

View

Was this helpful?

Vote up  26
Vote down  51

To whom can an appeal against the examination/test/check results be sent?

If an applicant does not agree with the result of his/her assessment, he/she can only resolve this problem at the national level.

An applicant cannot apply to the EASA management regarding a decision taken by his/her national aviation authority. Appeals to the Agency can only be made against decisions of the Agency.

Therefore the applicant should resolve this problem on the national level by sending his/her complaints to the national body dealing with complaints against state authorities.

View

Was this helpful?

Vote up  9
Vote down  13

Could the European Central Question Bank be published?

The Agency is the administrator of the European Central Question Bank (ECQB).

Taking into account that:

  1. Ownership of the copyright of the ECQB database is vested to the European Aviation Safety Agency; and
  2. Ownership of the contents of the database remains vested to its respective owners; and
  3. The possession, management and administration of the contents of the database have been fully vested in the hands of the Agency; and
  4. The contents of the database are confidential and have been treated as such without interruption.

The Agency, acting in the capacity of copyright owner and administrator of the database, enjoys the exclusive right among others, to prevent temporary or permanent reproduction by any means and in any form, as well as to prevent any form of distribution to the public of the database or of copies thereof.

It is the opinion of the Agency that such reproduction and distribution would endanger the functionality and integrity of the applicable examination system and would invalidate the associated substantial investment in both intellectual and monetary terms.

View

Was this helpful?

Vote up  16
Vote down  39

How can a military licence be converted to a civilian one?

The EU rules for recognising military licences can be found in Commission Regulation (EU) No 1178/2011 on Aircrew. Article 10 states that the knowledge, experience and skill gained in military service shall be credited towards the relevant requirements of Part-FCL in accordance with the principles of a credit report established by the competent authority of the Member State where a pilot served, in consultation with the Agency.

Therefore, the competent authority of the Member State where the pilot served should be contacted and asked for the provisions applicable for such credits.

View

Was this helpful?

Vote up  11
Vote down  16

Which licence do I have to hold to become a TRI on a multi pilot aeroplane (MPA)?

The prerequisites to obtain and hold any TRI rating are regulated in FCL.915.TRI. There it is stated in a) that an applicant for a TRI rating shall hold a CPL, MPL or ATPL pilot licence on the applicable aircraft category.

View

Was this helpful?

Vote up  11
Vote down  4

Can a co-pilot apply for a TRI rating on a multi pilot aeroplane (MPA)?

Yes, but the rating has to be restricted to simulator training only. The reason is that FCL.915 b) (3) stipulates that all instructors providing flight training in an aircraft have to be able to act as PIC during the training flight which would not be allowed to a co-pilot.

View

Was this helpful?

Vote up  20
Vote down  0

Upset Prevention and Recovery Training

Which pilots need to undergo what kind of UPRT?

The different ‘levels’ of UPRT (please refer to the FAQ ‘What is UPRT?’) will be integrated into pilot training as follows:

  • basic UPRT
    • all modular and integrated CPL and ATP training courses for aeroplanes as well as the integrated MPL training course
       
  • advanced UPRT course’
    • Part of; 
      • integrated ATP course
      • integrated MPL course
    • Perquisite to;
      • training courses for single-pilot class or type ratings operated in multi-pilot operations
      • training courses for single-pilot high performance complex aeroplanes
      • training courses for multi-pilot aeroplanes
  • class-or type-related UPRT
    • training courses for single-pilot high performance complex aeroplanes
    • training courses for multi-pilot aeroplanes
    • bridge course for extending privileges on a single-pilot aeroplane to multi-pilot operations
View

Was this helpful?

Vote up  14
Vote down  3

From when UPRT will be mandatory?

The entry-into-force / start of applicability of the new UPRT provision will depend on the progress of the rulemaking process following the publication of EASA Opinion No 06/2017 on 29 June 2017. For the time being, 8 April 2019 is envisaged as the day from which the new regulatory framework on UPRT will apply. Transitional provisions will allow ongoing courses to be finished pursuant to the rules as in force today.

View

Was this helpful?

Vote up  21
Vote down  3

To which extend flight synthetic training devices (FSTDs) can be used for UPRT?

Training and checking of UPRT exercises within the validated training envelope of the particular FSTD will be possible. In this context, it needs to be highlighted that the revised Part-FCL requirements will mandate the conduct of ‘approach-to-stall’ exercises only, with no obligation to conduct ‘post-stall’ exercises.

For further information, please refer to EASA Opinion No 06/2017, Section 2.3.8.

View

Was this helpful?

Vote up  7
Vote down  1

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

EASA Opinion No 06/2017 aims at integrating UPRT at various stages of a professional pilot’s career. The proposed new provisions of Part-FCL will therefore not be applicable to training courses for the light aircraft pilot licence (LAPL) and the private pilot licence (PPL).

However, in order to address the fact that loss of control in-flight is still a major issue in general aviation, EASA intends to revise the existing AMC/GM published with regard to the provisions of Part-FCL, with the objective to integrate basic UPRT elements into existing training syllabi for the LAPL and the PPL.

For further information, please refer to EASA Opinion No 06/2017, Section 2.3.1.

View

Was this helpful?

Vote up  8
Vote down  1

What is UPRT?

UPRT stands for aeroplane ‘upset prevention and recovery training’ and constitutes a combination of theoretical knowledge and flying training with the aim of providing flight crew with the required competencies to both prevent and to recover from situations in which an aeroplane unintentionally exceeds the parameters for line operation or training (aeroplane upsets).

With the objective to introduce different ‘levels’ of UPRT at various stages of a professional pilot’s career, EASA has published its Opinion No 06/2017 and is currently revising the existing acceptable means of compliance (AMC) and guidance material (GM) published with regard to the provisions of Annex I (Part-FCL) to Regulation (EU) No 1178/2011 as follows:

  • Basic UPRT will exercises to be integrated in all CPL and ATPL training courses as well as the MPL training course.
  • An ‘advanced UPRT course’ will include at least 5 hours of theoretical instruction as well as at least 3 hours of dual flight instruction in an aeroplane, with the aim to enhance the student’s resilience to the psychological and physiological aspects associated with upset conditions.
  • Class- or type-related UPRT during class or type rating training will address the specificities of the relevant class or type of aeroplane.
View

Was this helpful?

Vote up  25
Vote down  15

Performance-based Navigation applicability

On which learning objectives will my theoretical knowledge training and exam for the instrument rating be based?

Until the 25 August 2018 all training courses follow the published learning objectives without PBN requirements. After this date Commission Regulation (EU) No 2016/539 applies and the IR training courses shall contain also the PBN elements. 

View

Was this helpful?

Vote up  43
Vote down  18

When can I apply to my competent authority for a PBN extension to my instrument rating?

After the 25 August 2018, when the Commission Regulation (EU) No 2016/539 applies and the applicant fulfils the relevant training and checking requirements.  

View

Was this helpful?

Vote up  30
Vote down  33

When does my approved training organisation have to comply at the latest with the PBN requirements?

The aircraft and FSTDs used for training have to comply with the requirements at the latest on 25 August 2018 if the training contains the required PBN elements. Approved training organisations providing training that started before 25 August 2018 may continue to train towards an IR until 25 August 2020. Such an IR cannot contain PBN privileges. 

View

Was this helpful?

Vote up  30
Vote down  6

When can an ATO apply for an approval of a new course and on which learning objectives will the course be based?

The PBN related amendment to the Aircrew Regulation was published with Regulation (EU) 2016/539 and entered into force on 7 April 2016. Since this date an IR course including PBN privileges can be approved to an ATO provided that the course complies with the requirements specified in Regulation (EU) 2016/539 and the associated AMCs. But the course can only start after the entry into force of the PBN related elements of the Regulation (25 August 2018).

View

Was this helpful?

Vote up  37
Vote down  8

When does my instrument rating have to include PBN privileges to be allowed to fly in IFR conditions ?

IR holders who want to fly PBN procedures have to hold PBN privileges from 25 August 2018. 

Pilots who fly on routes and approaches that do not require PBN privileges may continue to fly on an IR without PBN privileges until 25 August 2020. 

All IRs shall contain PBN privileges from 25 August 2020.

 

View

Was this helpful?

Vote up  65
Vote down  21

How should the Pilot’s PBN privileges be documented?

The completion of all requirements shall be entered in the pilot’s logbook or equivalent record. An equivalent record for pilots who do not record their flight time in an individual logbook but rely on the operator’s records for this purpose may use an extract of this record. (Commission Regulation (EU) 2016/539, Article 4a, (4)).

View

Was this helpful?

Vote up  13
Vote down  2

How does my national authority endorse the PBN privileges to my IR?

Please refer to the answers provided by the Member States in the table: Link 

View

Was this helpful?

Vote up  5
Vote down  5
Back to top

Medical

Where can the aero-medical requirements for ATCOs be found?

The requirements for Air Traffic Controllers’ aero-medical certification can be found in Annex IV –PART ATCO.MED– of the Regulation (EU) 2015/340.

View

Was this helpful?

Vote up  2
Vote down  1

Who can perform the Class 1 aero-medical examination?

Initial Class 1 aero-medical examination can be performed only at an Aero-medical centre (AeMC) certified to perform class 1 aero-medical examinations. The aero-medical examination for the renewal or revalidation of the medical certificate can be performed by either an AeMC or a properly authorized aero-medical examiner (AME).

View

Was this helpful?

Vote up  14
Vote down  16

Who can perform the Class 3 aero-medical examination?

Initial Class 3 aero-medical examination can be performed only at an Aero-Medical Centre (AeMC) certified to perform class 3 aero-medical examinations. The recurrent aero-medical examination can be performed by either an AeMC or a properly authorized aero-medical examiner (AME).

View

Was this helpful?

Vote up  6
Vote down  0

Who can perform the Class 2 and LAPL aero-medical examination?

All Class 2 and LAPL aero-medical examination can be performed by any AeMC or AME authorized to perform aero-medical examinations for aircrew. In addition to that, subject to national provisions, LAPL aero-medical examinations may be performed by General Medical Practitioners (GMPs).

View

Was this helpful?

Vote up  10
Vote down  3

Who can perform the Cabin crew aero-medical assessment?

Cabin Crew aero-medical assessment can be performed by any AeMC or AME authorized to perform aero-medical examinations in accordance with Regulation (EU) 1178/2011. In addition to that, subject to national provisions, aero-medical examinations and assessments may be performed by Occupational Health Medical Practitioners (OHMPs).

View

Was this helpful?

Vote up  5
Vote down  0

Do you have a list of certified AeMCs and AMEs in Europe?

No, EASA does not have any list of available AeMCs and AMEs. Nevertheless you should be able to find the list of AeMCs and AME on Competent Authorities’ web-sites for each Member State. The list of Member States and links to the competent authorities web sites can be found at this link.

View

Was this helpful?

Vote up  6
Vote down  7

Is there any AeMC available outside Europe?

No, to this moment EASA did not authorize any AeMC in third countries.
View

Was this helpful?

Vote up  3
Vote down  6

Where can the aero-medical requirements for Pilots and Cabin Crew be found?

The requirements for Aircrew aero-medical certification can be found in Annex IV – Part-MED – of the Regulation (EU) 1178/2011.

View

Was this helpful?

Vote up  15
Vote down  28

May I exercise the privileges of my PPL licence if I have a Class 1 medical certificate?

Yes, the Class 1 medical certificate includes Class 2 and LAPL privileges.

View

Was this helpful?

Vote up  4
Vote down  0

May I exercise the privileges of my PPL licence if I have a Class 3 medical certificate?

No, the Class 3 medical certificate does not include Class 2 privileges. In order to exercise the privileges of or undertake solo flights for a PPL licence you need to hold a valid Class 2 or Class 1 medical certificate.

View

Was this helpful?

Vote up  7
Vote down  0

If I undertake my aero-medical examination in another Member State than the state that issued my licence do I need to validate resulting medical certificate with my licensing authority?

No, if you hold a valid medical certificate issued by an AME authorized by an EASA State then no validation is needed, the medical certificate shall be recognized by all Member States without additional proceedings.
View

Was this helpful?

Vote up  52
Vote down  0
Back to top

Flight Simulation Training Devices (FSTD)

The CS-FSTD(A) - issue 2 was published on 3rd May 2018. When does the applicant/operator need to comply with issue 2?

Article 2 of the ED Decision 2018/006/R) states:
“This decision shall enter into force on the day following that of its publication in the Official Publication of EASA.”, which is the 4th of May 2018.
It means that the decision has been adopted and published - thus producing legal effects -, but is not necessarily mandatory on the date of entry into force. From that date on you may use Issue 2 for the qualification of a device, however, the use of the initial issue of CS-FSTD(A) is still possible.

The date when CS-FSTD(A) issue 2 becomes mandatory is the date of applicability of the ED decision. This date will be the “applicability date of the related Commission Regulation (which has been prepared based on EASA Opinion No 06/2017) that introduces new requirements on loss of control prevention and recovery training (UPRT) into Commission Regulation EU 1178/2011”.
The publication of this Commission Regulation is still pending but is expected for April 2019 (unless the date is further extended due to delays with the regulation).

From this date, any application for initial FSTD qualifications (letter of application) shall be against CS-FSTD(A) issue 2, in accordance with ORA.FSTD.210 (a)(1):
“The qualification basis for the issuance of an FSTD qualification certificate shall consist of: (1) the applicable Certification Specifications established by the Agency that are effective on the date of the application for the initial qualification;”

View

Was this helpful?

Vote up  14
Vote down  2
Back to top

General

Where can I find definitions for ‘shall’, ‘must’, ‘should’ and ‘may’, as used in the Agency’s rulemaking publications?

This question relates to the English writing standards used in Community legislation. The following link gives access to the English Style Guide prepared by the European Commission’s Directorate-General for Translation. Guidance concerning the use of verbs in legislation can be found in paragraphs 10.19-10.27, as well as an explanation of the distinction between the verbs used in enacting or non-enacting terms. For more information click here . The Joint Practical Guide of the European Parliament, the Council and the Commission also gives guidance on the principles of drafting Community legislation.

View

Was this helpful?

Vote up  23
Vote down  148

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

The Lisbon Treaty, the latest primary treaty at EU level, was signed on 13 December 2007 and entered into force on 1 December 2009.

The European Union has been given a single legal personality under this Treaty.

Previously, the European Community and the European Union had different statutes and did not operate the same decision-making rules. The Lisbon Treaty ended this dual system.

On practical terms, all EU legislation has the reference to the EU since 1 December 2009. Up till then, the reference was made to the European Community (EC) as only this body had legal personality.

View

Was this helpful?

Vote up  103
Vote down  38

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.

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 interpretation and application of the Basic Regulation, its IRs, AMCs and the CSs.

View

Was this helpful?

Vote up  152
Vote down  9

Implementing Rules are available in all of the national languages of the EASA Member States. How is the quality of these translations assured? Who is responsible for the translations?

EASA is committed to facilitating the production of good quality translations. To ensure this and, where necessary, to improve, EASA has set up a Translation Working Group in 2008. This Working Group is made up of members of the National Aviation Authorities (NAAs), the Translation Centre of the EU Bodies (CdT), as well as EASA staff members. Also, EASA in cooperation with NAAs and CdT, is developing glossaries in the different aviation domains, such as Air Operations or Air Traffic Management, to enhance the quality of translations. The Member States also contribute to this project in order to capitalise on existing material and experience.

The final responsibility for translations lies with the EU Commission. The correction of translation mistakes of the Implementing Rules follows the same formal procedure as for their adoption: 1. preparation of the proposal, 2. interservice consultation, 3. committee, 4. scrutiny of European Parliament and of European Council, and 5. adoption. For minor mistakes, the procedure may be shorter. In any case, the linguistic changes will have to be agreed by the Commission’s translation services. These linguistic services will check that no substantial change is introduced, that the term used is acceptable according to an internal translation code or that the same change is included in all linguistic versions.

View

Was this helpful?

Vote up  9
Vote down  4

What is the progress of a regulation towards publication?

The Agency drafts regulatory material as Implementing Rules, Acceptable Means of Compliance, Guidance Material and Certification Specifications. These are available for consultation (as Terms of Reference, Notices of Proposed Amendment and Comment Response Documents). After consultation, the Implementing Rules are sent to the European Commission as Opinions.

Following publication of the Opinions, responsibility for completing the decision-making process prior to the Regulation’s publication in the Official Journal of the European Union passes onto the European Commission. The Opinions’ progress can be followed via the European Commission’s comitology website. It is advisable to search by year and for the committee dealing with these Opinions: Committee for the application of common safety rules in the field of civil aviation. As several Opinions may be negotiated in one such committee meeting, it is difficult to search by rule or title.

Once the committee has adopted the draft regulation, it is passed on to the European Parliament and Council for scrutiny. Further information and links to the documents under scrutiny can be found via the European Parliament’s Register of Documents.

The Agency is responsible for finalising the associated Acceptable Means of Compliance (AMC), Guidance Material (GM) and Certification Specifications. As these need to take into account any changes made to the Cover Regulation and Implementing Rules by the EASA Committee, European Parliament and Council, the Decisions are published on the Agency website shortly after the date when their corresponding regulation has been published in the Official Journal.

The Agency also publishes a rulemaking programme, listing the tasks that are ongoing and advance planning. It is available here.

View

Was this helpful?

Vote up  39
Vote down  4

What is the comitology procedure?

Under the Treaty the European Commission is responsible for the required implementation of Community legislation in many areas. When exercising these delegated powers it is often obliged to work with national civil servants appointed by Member States in different committees. These committees, which are a forum for discussions and the voicing of opinions, are chaired by the European Commission.

For the implementation of Regulation (EC) No 216/2008 (the Basic Regulation, BR) the European Commission is assisted by the EASA committee and the Single European Sky committee. Another committee of importance as regards aviation safety is the Air Safety committee, which is best known for being the guardian of the so called ‘Safety list’ as provided by Directive 2004/36/CE of the European Parliament and of the Council of 21 April 2004 on the safety of third-country aircraft using Community airports.

The procedures which govern the work of these committees follow the standard procedures established in Regulation (EU) 182/2011 of the European Parliament and of the Council of 16 February 2011 laying down the rules and general principles concerning mechanisms for control by Member States of the Commission’s exercise of implementing powers. It replaces Decision 1999/468/EC. This Regulation introduces a new ‘comitology’ procedure, which gives somewhat amended rights to Member States to control the way the Commission uses its delegated powers. The powers conferred to the European Parliament have been reduced slightly by the new Regulation and an Appeals Committee has been introduced in case no agreement can be reached in the committee. The latest comitology regulation can be consulted using the following link.

In principle the new comitology works as follows:

For the adoption of detailed implementing rules, the basic act may provide for the application of the examination procedure or the advisory procedure, taking into account the nature or the impact of the implementing act required.

The examination procedure applies, in particular, for the adoption of:

  1. Implementing acts of general scope;
  2. Other implementing acts relating to:
    1. programmes with substantial implications;
    2. the common agricultural and common fisheries policies;
    3. the environment, security and safety, or protection of the health or safety, of humans, animals or plants;
    4. the common commercial policy;
    5. taxation.

The advisory procedure applies, as a general rule, for the adoption of implementing acts not falling within the ambit of the aforementioned areas. However, the advisory procedure may apply for the adoption of the implementing acts referred to there in duly justified cases.

For the adoption of EASA implementing measures in the field of ATM/ANS and aerodromes only one procedure is relevant: the examination procedure.

However, to understand comitology in conjunction with the ATM and aerodromes regulatory processes it should be taken into account that the BR still refers to the old comitology process. In particular Articles 8a (Aerodromes) and 8c (Air Traffic Controllers) refer to Article 65(4) of the BR, which reads as follows:

Where reference is made to this paragraph, Article 5a (1) to (4), and Article 7 of Decision 1999/468/EC shall apply, having regard to the provisions of Article 8 thereof.

Under the old regime this was dealt with by Single Sky and EASA committees using the Regulatory Procedure with Scrutiny.

Article 8b of the BR, however, refers to Article 5(3) of Regulation (EC) No 549/2004, which reads as follows:

Where reference is made to this paragraph, Articles 5 and 7 of Decision 1999/468/EC shall apply, having regard to the provisions of Article 8 thereof.

This was dealt with by the Single Sky Committee under the Regulatory Procedure (without scrutiny).
As said before, the new Regulation 182/2011 repeals the old comitology Decision, however, its Article 12 indicates that:

  • The effects of Article 5a of Decision 1999/468/EC shall be maintained for the purposes of existing basic acts making reference thereto.

So the regulatory procedure with scrutiny stays.

Article 13 indicates:

c. where the basic act makes reference to Article 5 of Decision 1999/468/EC, the examination procedure referred to in Article 5 of this Regulation shall apply ….

This means that the examination procedure replaces the old regulatory procedure. However, the examination procedure does not differ very much from the regulatory procedure. The whole procedure stays with the Single Sky committee and the EASA committee, even if no agreement is reached. It may in that case go to an appeal committee. In exceptional cases there may even be a consultation round by the Commission amongst the Member States. The Council is no longer involved. Parliament is involved only at a distance.

Conclusion:

Procedures applicable to aerodromes rules and ATCO licensing will hardly change. 
Procedures applicable to ATM/ANS rulemaking will stay within the SSC, with possibility of appeals committee; there is no Council involvement; Parliament’s involvement only on distance.

View

Was this helpful?

Vote up  10
Vote down  10

What does cover regulation mean?

Implementing rules are Commission Regulations. They are usually composed of a short introductory regulation, colloquially known as ‘cover regulation’, and Annexes thereto, containing the technical requirements for implementation. In the EASA system, these Annexes are usually called Parts (e.g. Part-21 is an Annex to Regulation 1702/2003).

The ‘cover’ regulation is usually short (3-4 pages) and it includes:

  • Considering clauses (“whereas”), explaining the principles and considerations that lead the legislator when adopting the Regulation;
  • A description of the objective and scope of the regulation;
  • Definitions that are used throughout the Regulation and its Annexes;
  • the establishment of the applicability of its annex(es)
  • Conversion and transition measures
View

Was this helpful?

Vote up  36
Vote down  3
Back to top

Continuing Airworthiness

Interpretation and policy papers

Continuing airworthiness - General

What is the difference between Commission Regulation (EU) No 1321/2014 of 26 November 2014 and Commission Regulation (EC) No 2042/2003 as amended?

Commission Regulation (EU) No 1321/2014 of 26 November 2014 is an official consolidated version of Commission Regulation (EC) No 2042/2003 and its amendments published up to date, as follows:

  • (EC) No 707/2006;
  • (EC) No 376/2007;
  • (EC) No 1056/2008;
  • (EU) No 127/2010;
  • (EU) No 962/2010;
  • (EU) No 1149/2011; and
  • (EU) No 593/2012.

You can access the various lingual and format versions at: http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1421934905395&uri=CELEX:32014R1321 .

Commission Regulation (EU) No 1321/2014 (recast) repeals Regulation (EC) 2042/2003 and its amendments. Its date of application is 20 days after 17/12/2014 (date of publication in the Official Journal).

Some subsequent changes in that new Regulation compared to the old one(s) were deemed necessary but remain very minor, without any impact in its implementation. The following items can be mentioned:

  • The Cover Regulation, i.e. the recitals and articles at the beginning of the document have been adjusted;
  • Article 6(3) of Regulation (EU) 1321/2014 introduces new provisions related to the minimum syllabus of certifying staff type rating training in the operational suitability data for the relevant type in accordance with Regulation (EU) No 748/2012, which further refers to Part-66 Appendix III points 1 (a)(ii) and (b)(ii).
  • Some editorial corrections were introduced with no effect in its implementation.
  • Regulation (EU) No 1321/2014 contains references to Regulation (EC) 2042/2003 in the approval certificates (EASA Forms). These references will be changed with the next amending regulation planned before summer 2015.Until that moment the templates for the certificates and forms shall be used as published in Regulation (EU) 1321/2014

 

The existing approved AMCs/GMs covered by the EASA Decisions,  which complemented (EC) 2042/2003 as amended , keep on being valid for newly published Commission Regulation (EU) 1321/2014.

View

Was this helpful?

Vote up  86
Vote down  10

As regard to the approval of the continuing airworthiness organisations, what is the sharing of responsibilities between EASA and the EASA Member States? How to get a list of the EASA approved continuing airworthiness organisations?

According to Article 20 of (EC) No.216/2008 on common rules in the field of civil aviation and establishing a EASA, the Agency is responsible for :

  1. The management of all applications for organisations whose principal place of business is outside the territory of the EASA Member States (MS) for EASA Part-145 maintenance organisation approvals (MOA), EASA Part-147 maintenance training organisation approvals (MTOA), EASA Part-M Subpart G continuing airworthiness management organisation (CAMO) and EASA Part-M Subpart F approvals (Subpart F).
  2. The oversight of related certificates and their continued surveillance.

These activities are as follows:

  • MOA: Part-145 organisations ('Foreign', USA and Canada ),
  • MTOA: Part-147 organisations,
  • CAMO: Part-M Subpart G organisations,
  • Subpart F : Part-M Subpart F organisations.

Such organisations, generally nicknamed as “foreign” organisations, are managed by EASA in accordance with the relevant Annexes of Regulation (EU) No.1321/2014 and the associated EASA procedures. For more information, see Continuing-airworthiness-organisations  where the lists of such  “foreign” organisations are available as well as the fees and charges Regulations.

The management of all applications for organisations whose principal place of business is inside the territory of the EASA Member States (MS) is performed by the competent authorities of these MS.

Therefore, information about continuing airworthiness management organisations, maintenance organisations and maintenance training organisation which have principal place of business within any of the EASA MS is kept up-to-date by  the competent authorities from these EASA MS. You may contact these authorities at http://easa.europa.eu/the-agency/member-states or consult their public websites when the MS accepted to publish these lists on a voluntary basis.

View

Was this helpful?

Vote up  18
Vote down  15

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

The European Implementing Rules for continuing airworthiness(EU) 1321/2014 do apply to
third-country registered aircraft if:

  • The regulatory safety oversight of such aircraft has been delegated to one of the Member States (*), in which case Part-M (Annex I) applies [see Article 3(1) of (EU) 1321/2014] or
  • The aircraft is dry leased-in by an EU licenced air carrier, in which case Part-T (Annex Va) is applicable [see Article 3(5) of (EU) 1321/2014].

When third-country registered aircraft are not captured by above-mentioned cases, it is advised to go back to the foundation of the EASA system, namely the Basic Regulation (BR), Regulation (EC) 216/2008.

Reference should be made to Annex IV (Essential requirements for air operations) in accordance with Article 8(1) for the aircraft described in Article 4(1)(c). Point 6 in Annex IV of the BR describes air operations requirements related to continuing airworthiness, such as the requirement for release to service, pre-flight inspection, maintenance programme, records, … Being part of an Annex relevant to air operations, these requirements have to be overseen by the competent authority of the state of the operator.

Furthermore, as required by point 8 of Annex IV of the BR for complex motor-powered a/c (as defined in Article 3(j)) and forcommercial operation (as defined in Article 3(i)), the continuing airworthiness tasks (including maintenance) shall be controlled by an organisation, whose obligations (such as establishment of an organisation manual) are specified in point 3.a. of Annex I and point 8.g. of Annex IV of the BR.

(*) – The transfer of a state’s oversight responsibility is addressed in Article 83 bis of Chicago Convention. 

View

Was this helpful?

Vote up  3
Vote down  2

Part-M

Part-M: General

Maintenance for each type of aircraft/operation

 

 

 

MAINTENANCE

Commercial operations

Licenced air carriers [1]

Maintenance to be performed by Part-145 organisations

Commercial specialised operations or CAT other than licenced air carriers or commercial ATOs

Complex motor-powered aircraft [2]

Maintenance to be performed by Part-145 organisations

Other than complex motor-powered aircraft (CMPA)

Maintenance to be performed by:

  • Part-M Subpart-F organisations; or,
  • Part-145 organisations.

Other than commercial operations

CMPA

Maintenance to be performed by part-145 organisations

Other than CMPA and limited operations [3]

Maintenance may be performed by:

  • Part-145 organisations,
  • Part-M Subpart-F organisations,
  • Independent certifying staff, or,
  • Pilot-owner maintenance [4]

[1] Licensed 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)

[4] Only limited to non-CMPA of 2730 kg MTOM and below

View

Was this helpful?

Vote up  48
Vote down  10

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 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 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).

View

Was this helpful?

Vote up  92
Vote down  20

Can an independent certifying staff maintain ELA1 aircraft used for commercial operations (such as ATO)?

No, ELA1 aircraft used for commercial operations cannot be maintained by independent certifying staff because in accordance with M.A.201(i) commercial operations require maintenance release by an organisation (part-M subpart-F or part-145 approved).

View

Was this helpful?

Vote up  32
Vote down  9

Which are the correct statements to be written in block 11 of EASA Form 1 after maintenance?

Appendix II to part-M describes the following 4 permissible entries in block 11 of EASA Form 1:

  • Overhauled,
  • Repaired
  • Inspected/tested
  • Modified

The meaning of “Inspected/Tested” status is inspected and/or, if applicable, tested as it described in provisions of part-M/part-145.  Besides that, block 12 in the EASA Form 1 should contain the detailed information on the status/work described in block 11.

View

Was this helpful?

Vote up  106
Vote down  27

Can a licenced pilot without a valid medical certificate perform pilot-owner maintenance?

This question arises because of the different understandings of license validity in Commission Regulation (EU) No 1178/2011 (Aircrew) and No 1321/2014 (Continuing Airworthiness).

In Reg. (EU) 1321/2014, the pilot-owner authorisation described in M.A.803 assumes that a pilot has sufficient technical knowledge to perform certain maintenance tasks. While exercising such pilot-owner authorisation, the pilot-owner even further develops his/her competency in maintenance. Hence, in the case where the medical examination has not been conducted or not been passed and the licence has therefore lost its validity, it is the intent of the rule to allow the pilot-owner to continue using this authorisation as long as he/she still considers himself/herself physically fit (including good visual acuity) and competent to carry out such maintenance (ref. point (a)(2) of Appendix VIII to Part-M).

This is the reason why a new point (5) was introduced in AMC M.A.803 in 2016 (ED Decision 2016/011/R) stating: “not holding a valid medical examination does not invalidate the pilot licence (or equivalent) required for the purpose of the pilot-owner authorisation”.

View

Was this helpful?

Vote up  3
Vote down  0

What are the responsibilities relevant to pre-flight inspection?

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)

Carry out pre-flight inspection satisfactorily

Pilot in command or another qualified person in case of Licenced Air Carrier (e.g. CAMO staff or contracted organisation)

 

M.A.301(1)

Ensure pre-flight inspection is carried out

Owner or CAMO (according to M.A.201)

If CAMO contract the pre-flight inspection to another organisation, this activity is subject to the CAMO quality system

[AMC M.A.301(1) point (3)]

Ensure pre-flight inspection includes the actions necessary to ensure that the aircraft is fit to carry out the intended flight

AMC M.A.301(1) point(1) and (2) elaborates those actions

Provide training to ensure that pre-flight inspection is carried out adequately [AMC M.A.301(1) point (3)]

CAMO

Pre-flight inspection training described in the CAME in part 1.11 [‘Appendix V to AMC M.A.704’]

Additional information:

 

M.A.712(b)

Ensure pre-flight inspection is subject to the quality system

CAMO

This is important because the pre-flight inspection contributes in feeding the process of aircraft continuing airworthiness

 

Remark:
As per the definition of maintenance in article 2 point(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)]. 

View

Was this helpful?

Vote up  3
Vote down  0

Airworthiness review

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

Neither an ARC nor a recommendation can be issued with open findings. Each finding requires a corrective action before the issue of the ARC or recommendation. The corrective action should be adequate to the open finding and it should be carried out and verified by the airworthiness review staff (ARS) before the issue of the ARC/ recommendation.

View

Was this helpful?

Vote up  79
Vote down  20

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

As long as the conditions established for controlled environment (M.A.901 (b): continuously managed during the previous 12 months by a unique CAMO and maintained for the previous 12 months by part-145/part-M subpart F maintenance organisations or maintenance tasks referred to in point M.A.803(b) carried out and released to service by independent certifying staff (M.A.801(b)2) or pilot owner (M.A.801(b)3)  are met, the validity of the ARC can be extended for a period of one year. Should the ARC extension be anticipated more than 30 days, you will lose the continuity of the airworthiness review pattern, being the next date of expiry one year after the date of extension.

View

Was this helpful?

Vote up  58
Vote down  14

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:

  1. 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).
  2. 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.
  3. Such maintenance has been released as part of the annual inspection contained in the maintenance programme conducted together with the Airworthiness Review (for ELA1 aircraft not involved in commercial operations). Refer to M.A.901(l).

From regulatory perspective, cases 1 and 2 are explicitly considered by AMC M.A.707(a) [2nd bullet of point (5)] 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 is also Certifying staff. Such cases include for example standalone ARS as per M.A.901(g) or ARS personnel of an AMO with 145.A.75(f) or M.A.615(e) privilege.

Remark: iaw AMC M.A.710(b) and (c) points 1 and 2, 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.

 

View

Was this helpful?

Vote up  0
Vote down  0

Can the airworthiness review certificate (ARC) of the large aircraft be extended during the extensive maintenance/long term storage?

An ARC extension could be performed as long as:

  1. the conditions established for controlled environment (M.A.901 (b)) are met. This means:
    1. continuously managed during the previous 12 months by a unique CAMO, and
    2. maintained for the previous 12 months by Part 145 organisations.

AND

  1. there is no evidence or reason to believe that the aircraft is not airworthy, as stated in M.A.901(k).

Thus, the procedure for the extension established in the CAMO has to address verification of the compliance with 3 above mentioned conditions. An aircraft going through the lengthy maintenance/modification or long-term storage is not considered to meet the condition number 2.

View

Was this helpful?

Vote up  48
Vote down  22

CAMO 1 uses the anticipation when performing the airworthiness review or extension for 90 or 30 days correspondingly. After the issue or extension of the ARC, the aircraft is transferred during the anticipation period from CAMO 1 to CAMO 2. As the consequence CAMO 2 has solely continuously managed the aircraft for more than 12 months due to the term of the validity of the ARC accordingly being more than 12 month. Are the requirements of the M.A.901(b)(i) satisfied?

The intent of the article M.A.901(b)(i) is to define the ‘controlled environment’ by indicating that the aircraft must be managed during last 12 months by unique CAMO, which indirectly refers to a standard term of validity of the ARC.  Therefore, if the aircraft has been managed by more than one CAMO since the date of issue of the last ARC or the date of issue of the ARC extension, it actually indicates that controlled environment was discontinued.

In addition in accordance with M.A.710(d) the 90 days anticipation shall be used to allow the physical review to be performed during a maintenance check. However, the intention of the rule was never to address the transfer of the aircraft within those 90 days with the purpose of avoiding the forthcoming airworthiness review.  Concerning the 30 days anticipation for the ARC extension, point M.A.901(f) is intended for 2 consecutive extensions by the same CAMO managing the continuing airworthiness of the aircraft from the date of issue of the ARC, so the extended ARC could not be extended 2nd time by another organisation, because this constitutes a ‘breach’ of controlled environment.

View

Was this helpful?

Vote up  33
Vote down  12

Is EASA Forms 1 required during the import of the aircraft in the EU?

For the import of aircraft in the EU, the provisions of M.A.904 require the accomplishment of the airworthiness review, associated AMC M.A.904(a)(2) defines work to be performed in order to determine the airworthiness status of the aircraft.

When performing the airworthiness review there would be certain provisions of part-M where it might be not possible to show the full compliance with M.A.710 e.g. availability of EASA Form 1 for all relevant components. In such case, other releases to service or serviceable tags may be acceptable for the competent authority of the importing country.

Nevertheless, it must be ensured that the information required by M.A.305(d) related to the status of ADs, determination of remaining life, modifications and repairs is available (see also AMC M.A.305(d)).

View

Was this helpful?

Vote up  51
Vote down  4

Technical records

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

The term “back to birth” is not used in European regulations. The requirements that apply to a service life-limited component (see definition in AMC M.A.305) are basically stated in M.A.305 (e) and (h). All detailed maintenance records of a maintenance action (e.g. a restoration) must be kept until another maintenance action equivalent in scope (another restoration) is done, but never less than 36 months. Keep in mind that:

  • a service life limited component log card must be kept with all the relevant information, so the action should be recorded there, and
  • the records showing compliance with other requirements stated in M.A.305, e.g. an airworthiness directive, or any other information that could be affecting the configuration of the aircraft, must be retained too.
View

Was this helpful?

Vote up  96
Vote down  17

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 or 145.A.55(c) are required to be kept by an AMO (respectively Part-M/F organisation or Part-145 organisation). 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(h)(1) are those records, coming from the AMO1  having performed maintenance, required to be kept by the owner/operator (or the CAMO when required by M.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/CAMO 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/CAMO can demonstrate compliance with M.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/CAMO. 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. The AMO shall retain the records for 3 years, whereas the CAMO 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.

*: Transmitted records is a subset of AMO maintenance records provided to the CAMO. Certain transmitted records do not need to be kept as a record by the CAMO 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


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

 

 

View

Was this helpful?

Vote up  3
Vote down  0

Must the EASA Form 1 be kept for on-condition components ?

There is no specific requirement to retain the EASA Form 1 of such components unless needed to comply with the requirements set forth in M.A.305 (h)(1), (h)(4), (h)(5) and (h)(6) for determining the continuing airworthiness and configuration of the aircraft.

View

Was this helpful?

Vote up  40
Vote down  32

AMP (Aircraft Maintenance Programme)

What are the alleviations introduced by M.A.302(h) on the maintenance programme for General Aviation?

In accordance with M.A.302(h), for ELA1 aircraft not involved in commercial operation, the owner, whether he has contracted a CAMO or not [see M.A.201(i)], has the option not to submit the Aircraft Maintenance Programme (AMP) to the competent authority for approval, but instead ‘declare’ an AMP, subject to compliance with the conditions described therein. In this respect, the owner may decide to deviate from the applicable scheduled maintenance recommendations (see also remark below) without the need to justify such deviation(s), but under his/her full responsibility. Such declared AMP does not need to be sent to the competent authority.

In this scenario though, the declared AMP shall not be less restrictive than the ‘Minimum Inspection Programme’ (MIP) referred to in point M.A.302(i). 
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 ‘GM M.A.201(i), M.A.302(h) and M.A.901(l)’.

In addition, such declared AMP shall be reviewed annually and this review can be done either by the person who performs the airworthiness review, during the accomplishment of the airworthiness review, or by a CAMO if contracted to manage the continuing airworthiness of the aircraft [see M.A.302(h)5]. 

Besides, if during the airworthiness review it is observed that there are discrepancies on the aircraft linked to deficiencies in the content of the maintenance programme, the competent authority shall be informed and the AMP amended.

Remarks

  1. In accordance with M.A.302 and in particular M.A.302(h)(3), 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).
  2. In accordance with Part-M Appendix VIII point (b)(9), the tasks that are part of the annual or 100h check contained in the ‘Minimum Inspection Programme’ do not qualify for pilot-owner maintenance referred to in M.A.803.

References:
Please refer also to AMC M.A.302(e) (maintenance programme template), AMC M.A.302(h), GM M.A.302(h) and AMC M.A.302(i) (content of MIP).

Please refer to Article 2 (point k) of Regulation (EU) 1321/2014 for the definition of ELA1.

Please refer to Article 3 (point i) of Regulation (EU) 216/2008 (Basic Regulation) for the definition of commercial operation.
The agency also advises the owner who intends to transition from conventional to declared AMP to contact the competent authority for their guidance.

 

View

Was this helpful?

Vote up  16
Vote down  2

When does the interval for the next calendar aircraft maintenance check/task or the calendar interval for the next component check/overhaul starts?

In a normal scenario :

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

However, there may be a lot of different considerations that change the normal scenario and make the statements above no longer valid. For example:

Case 1: The interval of the maintenance task has been ‘extended’ using a procedure included in the aircraft maintenance programme and approved by competent authority (refer to Appendix I to AMC M.A.302 point 4). Such procedure is often referred as permitted variation or ’tolerance’. In this case the next due date calculated using the original due date.

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.

Case 3: The task is part of a maintenance check, where the duration of the check is significant compared to the interval of the task. For example, a check that lasts for 2 months and an inspection that has an interval of 3 months. In this case, it is reasonable to think that the performance of this task would need to be planned for the last days of the maintenance check, when possible. Otherwise, the inspection also can be done on the first day, but in that case, it is reasonable to expect that it will be released the same day (then the next due date would be 3 months after the CRS is signed). It also applies to the specific cases of mandatory tasks (ADs, CMRs, ALIs, etc.) defining repetitive action with a calendar limit.

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

View

Was this helpful?

Vote up  98
Vote down  45

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

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

This means that the owner/operator/CAMO 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(d)(ii)/(iii) 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 a 1-year review interval (annual review). 

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 CAMO, the CAME (Continuing Airworthiness Management Exposition) should describe the AMP revision policy (including ‘periodic review’) under point 1.2 [Appendix V to AMC M.A.704].

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.

View

Was this helpful?

Vote up  9
Vote down  1

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

Although the Member State’s competent authorities are responsible for approving the AMP, the intention of the rule is that they should not impose aeronautical instructions (such as national requirements) in addition to the instructions for continuing airworthiness (ICA) issued by the design approval holder during the certification process with the Agency. The Agency is, on behalf of the Member States, the competent authority for initial airworthiness as per article 20(1) of regulation (EC) 216/2008 (the EASA ‘Basic Regulation’). Following M.A.302(d)(ii), those ICA shall be the basis to develop an AMP.

Nevertheless, competent authorities may issue alternate instructions to ICA when such instructions aim to offer flexibility to the operator [AMC M.A.302(d) point (2)].

Additionally, the mentioned AMC facilitates the rare case, where there have been no ICA issued by the design approval holder for a particular aircraft, modification, repair or STC (Supplemental Type Certificate): competent authorities may issue relevant instructions for the AMP in this case.

 

Remarks:

  • The airworthiness (initial and continuing) of the aircraft referred to in Annex II to the Basic Regulation has to comply with the national rules of the state of registry, which may include ‘national requirements’.
  • If the AMP is self-declared, based on the M.A.302(h) alleviation for ELA1 aircraft not involved in commercial operation, it cannot be initially challenged by the competent authority and the owner assumes full responsibility for its content (including potential deviations to ICA - see FAQ n.43423).
  • There is no equivalent of US CFR Title 14 Part-43 Appendix E/Part-91 (§91.411) or Part-43 Appendix F/Part-91 (§91.413) in the EU system.
View

Was this helpful?

Vote up  2
Vote down  0

How is it possible to escalate AMP task intervals?

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(g) – see FAQ n.47406].
b) It should form part of the analysis of the effectiveness of the AMP (if required by M.A.301(4)),
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
      - formal reliability programme if required by M.A.302(f) 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 CAMO involved, those points also have to be emphasised within the CAME, as specified in Appendix V to AMC M.A.704.

Two different cases:
The escalation of AMP task intervals falls into the alternative instructions proposed by the owner/ CAMO [M.A.302(d) point (iii)] 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(d)] 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(d) point (iii).

Regarding case 2:
An indirect approval of the AMP through a CAMO 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(f) 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 and AMC M.B.301(b)’ point (4)].

View

Was this helpful?

Vote up  5
Vote down  0

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

For guidance on the escalation of AMP task intervals, please refer to FAQ no.48248.

Examples of alternative/ additional instructions to the Design Approval Holder’s (DAH) Instructions for Continuing Airworthiness (ICA) are listed below [see point (7) of AMC M.A.302(d)]:

1. De-escalation of task intervals (i.e. ‘more restrictive intervals’). Regardless of the source of the task, this may be eligible to indirect approval [see FAQ n.19061].

2. Additional scheduled maintenance tasks selected by the operator on voluntary basis (e.g. operator policy for interiors), or manufacturer recommendations outside ICA (e.g. Service Letter) linked to product improvements or maintenance practices... Depending on their nature, those tasks may be added, changed and deleted through the indirect approval [see FAQ n.19061].

Remark: Additional and de-escalated tasks may originate from the reliability programme as indicated in point (4) of AMC M.A.302(f).

3. Concerning changes in task type (e.g. from General Visual Inspection to Detailed Inspection, or from Operational Check to Functional Check), by analogy with the escalation [see FAQ no.48248] EASA recommends that for safety-related tasks such changes are directly approved by the competent authority. For non-safety related tasks, the competent authority may accept an indirect approval.

Finally, please be aware of the alleviations applicable for AMPs of ELA1 aircraft not involved in commercial operation, which are elaborated in FAQ n.43423.

View

Was this helpful?

Vote up  4
Vote down  0

CAMO (Continuing Airworthiness Management Organisation)

Quality manager for CAMO: Nomination, acceptance, qualification

The quality manager is considered nominated personnel according M.A.706 (c). The minimum qualification and experience requirements are contained in AMC M.A.706.

The nomination of the quality manager shall be performed using the EASA Form 4.

View

Was this helpful?

Vote up  50
Vote down  73

Are deputy nominated persons required in CAMO?

Neither M.A.706 (c) nor M.A.706 (d)  contain a specific requirement for the identification of deputy “nominated persons” as in part-145 (145.A.30(b)(4)). So, in principle, we could say that there is no requirement for the nomination or identification of deputy “nominated persons”.

Nevertheless, the CAMO needs to take into account the conditions for the continued validity of the approval contained in M.A.715, in particular point (a)(1) which refers to the continued validity of the approval provided the organisation remains in compliance with the requirements.

The CAMO should ensure that they remain in compliance during the absence of the nominated persons, this could be by identifying in the CAME  “one or several deputies” and the conditions under which the deputies will assume the responsibilities (this option could be acceptable for a short/medium absence). Another option would be to nominate another person. This would be necessary when the absence is going to be of considerable length and in this case the nomination and acceptance by the competent authority is done using the Form 4.

View

Was this helpful?

Vote up  58
Vote down  6

Under which condition can a CAMO use the indirect approval procedure to amend AMP (Aircraft Maintenance Programme) task?

The indirect approval procedures may only be used for:

- non-safety-related tasks as described in case 2 of FAQ n.48248 and example 3 of FAQ n.48249

- de-escalated tasks as described in example 1 of FAQ n.48249

- additional tasks as described in example 2 of FAQ n.48249

- editorial issues, typos, etc., (without having an effect on the AMP content)

In such case, as required by M.A.302(c) and M.B.301(c), the CAME (Continuing Airworthiness Management Exposition) must include, and the competent authority shall approve, a procedure describing as a minimum:
- Which AMP amendments are eligible for indirect approval
- Who in the CAMO is responsible to issue of the indirect approval
- How the amendments are controlled
- How and when the competent authority is informed of an amendment

Based on M.A.302(c), the indirect approval may only be used when:
- The aircraft is managed by a CAMO or there is a limited contract between the owner and the CAMO for the development and approval of the AMP;
   and
- The aircraft managed by the CAMO is registered in the Member State ensuring the oversight of this CAMO (unless an agreement exists between the competent authority for the AMP and the competent authority of the CAMO).

View

Was this helpful?

Vote up  5
Vote down  0

Do the maintenance contracts need to be submitted for the approval to the competent authorities after Commission Regulation (EU) 2015/1536 applies?

M.A.708(c) requires the CAMO to establish a written maintenance contract for CMPA or aircraft used for CAT or commercial specialised operations or commercial ATO operations.

The individual contracts need not to be submitted for approval to the competent authority. The competent authority shall approve the procedures for contracted maintenance as part of the CAME Part 3 and the basic information of the contracted maintenance should be included in a list of contracted maintenance organisations in the CAME part 5.4.

The amendment to the list mentioned in 5.4 may be managed through the indirect approval procedure.

Only for air carriers licenced in accordance with Regulation (EC) 1008/2008, the maintenance contracts need to be submitted to the competent authority as part of the package for initial application or for a change to the Air Operator Certificate as indicated in under M.B.701(a)(4).

View

Was this helpful?

Vote up  31
Vote down  8

Does the CAMO quality system need to be subject to monitoring?

Yes, the quality system is part of the activities of the CAMO and therefore it should be monitored.

Point M.A.712(b) requires that the quality system monitors:

  • that all CAMO activities are being performed in accordance with the approved procedures, and,
  • the continued compliance with requirement of part-M.

The quality system procedures are considered to be within these approved procedures . This implies that quality system must be subject to audits and the CAMO audit programme/plan needs to reflect this.

Besides that the audits to the quality system shall satisfy the requirement of independent audits. This is further explained in AMC M.A.712(b) point 8: the independence of the audits should be established by always ensuring that audits are carried out by personnel not responsible for the functions, procedures or products being checked. So, the quality manager cannot audit the quality system in terms of independence of the audit. Therefore, to audit the quality system, it is acceptable:

  • to use competent personnel from a different section/department in the same organisation not responsible for the quality function/procedure, or,
  • to contract the independent audit element of the quality system to another organisation or a qualified competent person, or,
  • that the quality system is monitored and certified against an internationally recognised quality standards by a certification organisation

The way the quality system is going to be audited has to be described in the CAME and approved by the competent authority.

View

Was this helpful?

Vote up  80
Vote down  13

Part-145

Part-145: General

Is Part-M applicable to approved Part-145 organisations?

Yes, Part-M is applicable to Part-145 organisations. Article 3(2) of Regulation (EU) 1321/2014 states that organisations and personnel involved in maintenance of aircraft and components shall comply with Part-M. Nevertheless, not all the requirements of Part-M are applicable to Part-145 organisations.

Part-145 organisations shall take into account the following requirements of Part-M:

  • M.A.201 (c) – Responsibilities
  • M.A.403 (b) – Aircraft defects
  • M.A.501 (a) & (c) & (d) – Installation
  • M.A.504 (a) & (b) & (d) & (e) – Control of unserviceable components

In addition, Part-145 refers to the following Appendixes of Part-M:

  • Appendix II to Part-M (EASA Form 1)
  • Appendix IV to Part-M (Class and rating system)
  • Appendix IX to AMC M.A.602 and AMC M.A.702 (EASA Form 2)
  • Appendix X to AMC M.B.602(a) and AMC M.B.702(a) (EASA Form 4)
View

Was this helpful?

Vote up  98
Vote down  11

What does the term ‘occasional’ mean in 145.A.75(c)?

Within the privilege described in 145.A.75(c) an aircraft maintenance organisation (AMO) may perform line maintenance activity in other-than-approved locations, provided it is considered as ‘occasional’. There is no formal definition of ‘occasional’ in the regulation, AMC and GM, but this privilege should be used to support an operator with which the AMO is already in contractual relation, when this operator needs line maintenance service for a short period at a new location due to a special occasion or particular reason (e.g. one-time flights, short term contracts/flight destination, flight schedule changes, special event at a particular location such as European athletics championship in Berlin, 6-12 August 2018, etc.).

Subject to the approval by the Competent Authority, the maintenance organisation should develop in the MOE (e.g. Chapter 2.24 Reference to Specific Maintenance Procedures) the generic procedures to be followed in such a case: how to assess whether the maintenance can be performed, availability of tools/ equipment/ material/ components/ maintenance data, staff, adequacy of the facilities, environmental conditions, quality system, record keeping, need to report these cases to the competent authority, etc. In addition, the procedure should include the criteria (e.g. maximum service duration without gap in the continuity; limitation in the repetition of the need* at one given location) to classify the activity as ‘occasional line maintenance’.

* In principle, the repetitive use of this privilege at the same location should not be considered, and for repetitive needs, an approved line station should normally be established at that location.

View

Was this helpful?

Vote up  2
Vote down  0

Quality system

Does the part-145 quality system need to be subject to monitoring?

Yes, the quality system is part of the activities of the part-145 organisation and therefore it should be monitored.

Point 145.A.65 (c) requires that the quality system monitors that the activities are being performed in accordance with the approved procedures. The quality system procedures are included within these approved procedures. This implies that quality system must be subject to audits and the part-145 organisation audit programme/plan needs to reflect this.

Besides that the audits of the quality system shall satisfy the requirement of independent audits. This is further explained in AMC 145.A.65(c)(1) point 11: the independence of the audits should be established by always ensuring that audits are carried out by personnel not responsible for the functions, procedures or products being checked. So, the quality manager cannot audit the quality system in terms of independence of the audit.
Therefore, to audit the quality system, it is acceptable to:

  • use competent personnel from a different section/department in the same organisation not responsible for the quality function/procedure, or,
  • contract the independent audit element of the quality system to another organisation or a qualified competent person.

The way the quality system is going to be audited has to be described in the MOE and approved by the competent authority.

View

Was this helpful?

Vote up  120
Vote down  27

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?

Yes, the dimensions of the damage and the removed/remaining material should be recorded. This is a very important information in order to assess whether further damage (adjacent or at the same spot) at a later stage would be allowable or not. In addition, it is a safeguard measure in order to be able to determine, during audits, whether the person correctly determined that the damage was within limits.

View

Was this helpful?

Vote up  98
Vote down  21

Can the subcontractor’s staff of a part-145 approved organisation issue an EASA Form 1?

One of the fundamentals of subcontracting activities is that, during such maintenance, the part-145 has been temporarily extended to include the subcontractor. Subcontracting can be done only if the part-145 has approved procedures to do it (145.A.75 (b)) and the MOE is amendment to show this new subcontractor.

A certificate of release to service can be signed by a person from the subcontractor who meets the part-145 approved maintenance organisation certifying staff standard approved in the MOE, which means:

  • The subcontractor’s staff (who does not need to hold a part-66 licence) must meet the authorisation criteria of the part-145 approved organisation, including the assessment of competence (knowledge, on-the-job performance and experience), continuation training and ongoing competency assessments.
  • The subcontractor’s staff must be authorised by the part-145 to issue an EASA Form 1

The certificate of release to service and the EASA Form 1 will always be issued under the maintenance organisation approval reference.

View

Was this helpful?

Vote up  139
Vote down  24

Release to service of NDT tasks by part-145 organisations

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.

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 or C 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, 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.

The certifying staff is qualified following the procedures established by the organisation, no need 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 “component” 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 / Engineering Order. The component certifying staff 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 D 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 D 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 an D 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.

View

Was this helpful?

Vote up  20
Vote down  6

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 AMO and contributes to demonstrate the overall capability of the organisation to perform maintenance.

The maintenance data either can be arranged directly by the part-145 maintenance organisation (AMO) or provided by the customer/operator as specified by 145.A.45(a) and 145.A.45(g). 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, as mentioned by 145.A.50(a) and 145.A.80 of the Regulation 1321/2014 correspondingly.

Additionally, as part of the obligation for maintenance records, used maintenance data shall be 
- recorded (in compliance with 145.A.55(c)) 
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)].
- accessible for auditing purpose 
to demonstrate that the organisation worked in compliance with their respective requirements.

View

Was this helpful?

Vote up  3
Vote down  2

Personnel requirements

Are the changes imposed by the EU Regulation 1149/2011 applicable to the Certifying staff qualified in accordance with Appendix IV to part-145?

  • The provisions of the paragraph 6 of the Article 6 of the Commission Regulation (EU) No 1321/2014 which were introduced by the Commission Regulation (EU) No 1149/2011 relating to the 10 years limit for obtaining the basic training/experience and 3 years requirement referred to in part-66 Appendix III para 1(a)(iv) relating to the type rating endorsement in part-66 Licence are not applicable to Certifying staff qualified in accordance with Appendix IV.
  • The practical type training is required in accordance with para 1 (e) of the Appendix IV to part-145, because in accordance with changes imposed by the Commission Regulation (EU) No 1149/2011, the type training shall consist of the theoretical training and examination and  practical training and assessment, as stated by item 1 of Appendix III to part-66.
  • On job training required by 66.45(c) is not applicable to the Certifying staff qualified in accordance with Appendix IV.
View

Was this helpful?

Vote up  18
Vote down  5

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

145.A.30(j)(3) is usually not applicable in case the CMRs included in an AD but it is not a “repetitive pre-flight airworthiness directive”,

145.A.30(j)(4) could be used for CMRs as long as all the applicable conditions are met. In particular:

  • The aircraft is away from a supported location.
  • Sufficient practical training has been carried out.
  • There is a procedure in the Maintenance Organisation Exposition.
  • The conditions of AMC 145.A.30(j)(4) are met (of other agreed with the competent authority which are consistent with this AMC). Please refer, in particular, to:
    • the point 2(i) where it says “minor maintenance or simple checks, and
    • the point 2((i)e of this AMC, which states “Any check/replacement involving simple techniques consistent with this AMC and as agreed by the competent authority”

 As a consequence, the competent authority should assess that the test is simple and that all the other conditions mentioned in 145.A.30(j)(4) and associated AMC/GMs are met.

View

Was this helpful?

Vote up  31
Vote down  10

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

The protected rights mentioned in paragraph 2(a) of the Appendix IV to Part-145 were included in the Regulation 2042/2003 for the persons who were already working in a Part-145 organisation in a location situated outside the EU before the entry into force of Part-66. These protected rights allowed those persons to continue exercising (inside that particular Part-145 organisation) the privileges of the certification authorisation issued by that Part-145 organisation without the need to comply with paragraphs 1(c) to 1(f).

If this person changed the employment to a different Part-145 approved organisation after the entry into force of Part-66 (i.e. 28 November 2003), the previous certification authorisation is not valid and he/she needs to receive a new one from the new Part-145 approved organisation. In this case paragraph 2 of Appendix IV is not applicable anymore.

This implies that any new or extended authorisation granted by AMOs to their C/S after the entry into force of Part-66 must comply with paragraphs 1(c) to 1(f) in particular regarding the type training certificates.

View

Was this helpful?

Vote up  14
Vote down  1

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, 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 (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 or B3 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 subparagraph 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 to be maintained together with the associated organisation procedures. In the case of certifying staff, this shall be accomplished before the issue or re-issue 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 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 re-issue 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.

AMC M.A.301-1

 

Personnel

References

Accountable Manager

145.A.30(a) point 3.

Nominated persons (including the Quality Manager)

145.A.30(b) point 3.

 

All personnel involved in any maintenance, management and/or quality audits.

 

145.A.30(e) and associated AMC/GM.

Appendix IV to AMC 145.A.30(e) and 145.B.10(3). (Fuel Tank Safety)

AMC 20-22. (EWIS)

Personnel who carry out and/or control a continued airworthiness non-destructive test of aircraft structures and/or components.

Personnel who carry out any other specialised task shall be appropriately qualified in accordance with officially recognised Standards.

 

145.A.30(f) and AMC 145.A.30(f).

Certifying staff and support staff

145.A.30(g) and (h) and associated AMC.

145.A.35(a) and AMC 145.A.35(a).

145.A.35(c) and AMC 145.A.35(c).

145.A.35(d) and AMC 145.A.35(d).

145.A.35(e) and AMC 145.A.35(e).

145.A.35(f) and AMC 145.A.35(f).

145.A.35(n) and AMC 145.A.35(n).

145.A.35(o) and AMC 145.A.35(o).

145.A.30(j) and associated AMC/GM.

Appendix IV to Part-145.

 

Personnel performing Pre-flight inspections (when the 145 organisation has an agreement with an operator)

AMC M.A.301-1

 

View

Was this helpful?

Vote up  124
Vote down  29

Part-66

Get a Part-66 licence

Which are the Part-66 licences?

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

LICENCE CATEGORY FOR: What:
 

Certifying the release of aircraft after:

 
A Minor scheduled line maintenance and simple defect rectification Line Maintenance
B1 Maintenance performed on aircraft structure, powerplant and mechanical and electrical systems, avionic systems requiring simple tests to prove their serviceability and no troubleshooting Line Maintenance
B3 Maintenance activities on non-pressurized aeroplanes of 2T 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
C Base maintenance activities Base Maintenance
  Support staff for:  
B1 B1 activities Base Maintenance
B2 B2 activities Base Maintenance
B3 B3 activities Base Maintenance

Part-66 EU Regulation can be found on the Agency website as Annex III to Commission Regulation (EC) 2042/2003 and can be ordered from the Technical Publications page.

View

Was this helpful?

Vote up  55
Vote down  23

How to get an EASA Part-66 Licence?

  1. In order to get an EASA Part-66 AML (Aircraft Maintenance License), an applicant needs:
    1. Basic knowledge (66.A.25);
    2. Basic experience (66.A.30).
  2. In order to get TR endorsed in the AML, an applicant needs:
    1. Type Training (Theoretical and Practical) (66.A.45)
    2. OJT for the first TR (66.A.45).

The following two schemes depict the most common paths and are for information only.  

  • The first scheme applies to Group 1 aircraft (B1 and B2 licence categories).
  • The second scheme applies to other than Group 1 aircraft (B1 and B2 licence categories).

NOTE: Aircraft groups are described in 66.A.5.

These schemes do not override Part-66 requirements nor capture all the possibilities (various licences, educations and experiences). The start and end of each phase can vary depending on individual cases.

For further and detailed information:

  • Refer to Part-66 and related AMC/GM; and
  • Consult the Competent Authority where you intend to apply for the AML.

NOTE:
An aircraft maintenance licence issued by a country other than EASA Member States cannot be rendered valid as EASA Part-66 AML.

NOTE:
Part-66 licences issued by the countries other than EASA Member States are not mutually recognised in European system.

Click on the pictures to zoom in.

View

Was this helpful?

Vote up  200
Vote down  147

How can I apply for an EASA Part-66 licence? What is required at the time of the application?

The initial application for a Part-66 aircraft maintenance licence shall be made to the competent authority of one of the member states. Please contact this competent authority for an application form (form 19) and specific details concerning the application. 
The form 19 shall be submitted to the Member States together with evidence of compliance with the requirements. Member states will specify the related fees and how compliance with the requirements shall be demonstrated.
See Part-66.A.15.10, 66.A.15, 66.A.25, 66.A.30, 66.A.45 and 66.A.70 and related AMC/GM.

An application for amendment or renewal of a Part-66 aircraft maintenance licence shall be made to the competent authority of the member states who issued the licence. Please contact this competent authority for an application form (Form 19) and specific details concerning the application. 
The form 19 shall be submitted to the Member States together with evidence of compliance with the requirements. Member states will specify the related fees and how compliance with the requirements shall be demonstrated.
See Part-66.A.15.10, 66.A.15, 66.A.25, 66.A.30, 66.A.40, 66.A.45, 66.A.50, and 66.A.70 and related AMC/GM.

View

Was this helpful?

Vote up  2
Vote down  5

Who is allowed to issue EASA Part-66 licences? Can I apply for a Part-66 licence to EASA?

EASA is not a licensing authority and therefore does not issue any licences. Part-66 licences are issued by the competent authorities of the EU Member States, plus Switzerland, Norway, Iceland and Liechtenstein. The list of the National Aviation Authorities and their contact details can be accessed here: http://easa.europa.eu/the-agency/member-states .

View

Was this helpful?

Vote up  20
Vote down  13

I want to work in an organisation located within the EU. Do I need a Part-66 licence?

According to the current rules, a Part-66 licence is required for:

  • certifying the release to service of maintenance of an aircraft;
  • work in maintenance organisations as support staff.

For other activities within a maintenance organisation, a Part-66 licence is not required. No Part-66 licence exists for components (based on article 5 of Commission Regulation (EU) No. 2018/1142).

Remark: Privileges on the basis of national requirements may be added in the Part-66 licence in section XIV. national privileges.

View

Was this helpful?

Vote up  2
Vote down  0

I am a colour-blind. Does this prevent me from getting a Part-66 licence or exercising my licence privileges?

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.

View

Was this helpful?

Vote up  50
Vote down  34

Does EASA plan to release regulation on the management of persons with specific learning difficulties (e.g. dyslexia, attention deficit disorder, hyperactivity,…) who wish to undertake aircraft maintenance training in a Part-147 approved training organisation with the aim of gaining a Part-66 license?

Anybody able to pass the basic knowledge examinations and fulfil the basic experience requirements can get a Part-66 licence. There are no additional conditions such as a medical certificate or any other proof regarding the mental or physical abilities. In other words, people with specific learning difficulties or physical impairments are not discriminated by Part-66 or Part-147.

Obtaining the licence does not give the certification privileges. Before granting such privileges, the maintenance organisation will have first to check the competence, including the assessment of the skills and abilities and considering the Human Factors principles. The scope of the certification authorisation will be commensurate to these competence/abilities. Please note that in some EU Member States additional occupational safety and health requirements may apply (working on heights, confined spaces, etc.).

EASA does not plan to amend the regulations taking into account the cases of people with special needs during examinations: a single Regulation cannot cover all individual cases. This is why Basic Regulation (EU) No. 216/2008 includes the possibility for the Member States to apply Article 14.4 or 14.6 for exemption, after evaluation of these individual cases. To illustrate, such exemptions in the past have been positively instructed for candidates with confirmed dyslexia (i.e. 25% additional time).

View

Was this helpful?

Vote up  21
Vote down  5

How can I get a Part-66 licence valid in the EU by conversion?

Either you are the holder of:

  • a national licence [66.A.305] or an approved maintenance organisation authorisation [66.A.310], that was valid in the Member State before the entry into force of the EASA regulation introducing the relevant Part-66 categories (see entry into force of the amendments of the regulation), or
  • JAR-66 licence, which will automatically be re-issued as Part-66 licences as they are deemed to have been issued in accordance with Part-66. This does only apply to JAR-66 licence issued by the countries listed on the Mutual recognition page.

Furthermore, 66.A.70 allows conversion of qualifications valid in a Member State in very specific and limited cases.

View

Was this helpful?

Vote up  0
Vote down  0

Basic Part-66 licence (without type rating)

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?

No, unless the basic knowledge got outside of the EU is acquired in a Part-147 training organisation approved by EASA, according to 66.B.405.

View

Was this helpful?

Vote up  37
Vote down  8

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

Maintenance experience should be written up in a manner that the reader has a reasonable understanding of where, when and what maintenance constitutes the experience. A task-by-task account is not necessary, but at the same time a bland statement such as “X years maintenance experience completed” would not be acceptable. A maintenance log book detailing the experience is desirable and some competent authorities may require such a log book (see AMC 66.A.10).  

Consequently, the format used to evidence the maintenance experience is not strictly defined in the rules and is left at the discretion of the competent authority issuing the licence. Hence, EASA advises you follow the instructions of the competent authority where you intend to apply for.

View

Was this helpful?

Vote up  19
Vote down  8

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?

It is not mandatory to gain maintenance experience in a Part-145 organisation. According to the AMC 66.A.30(a)(4), aircraft maintenance experience gained within different types of maintenance organisations (under Part-145, M.A. Subpart F, FAR-145, etc.) or under the supervision of independent certifying staff may be accepted by the competent authorities. This means that the aircraft maintenance experience may be accepted by the competent authority when such maintenance is performed in a maintenance organisation which does not necessarily hold an EASA Part-145 approval.

Furthermore aircraft maintenance experience gained outside a civil aircraft maintenance environment may include aircraft maintenance experience gained in armed forces, coast guards, police, etc., or in aircraft manufacturing. However, it is on the competent authority to evaluate whether this experience is acceptable.

Consequently, please contact the competent authority where you intend to apply for a licence, in order to check whether the basic experience would be acceptable.

See Part-66.A.30 and related AMC/GM.

View

Was this helpful?

Vote up  2
Vote down  0

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.

View

Was this helpful?

Vote up  34
Vote down  12

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?

According to Commission Regulation (EU) No 1149/2011 of 21 October 2011 (amending Regulation (EC) No 2042/2003), the basic examinations shall be passed and experience shall be acquired within the ten years preceding the application for an aircraft basic licence.
The new regulation also states that for the purpose of time limits related to basic knowledge examinations, basic experience acquired before the Regulation applies, the origin of time shall be the date by which this Regulation applies, which is 01/08/2012 (which means until 31/07/2022).

View

Was this helpful?

Vote up  84
Vote down  20

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?

The requirements to extend a Part-66 licence with a category A1 to B1.1 are:

  • the knowledge demonstration of those basic modules, which are of higher level for B1.1 (see Part-66 Appendix I); and
  • the demonstration of experience required by Appendix IV to Part-66:

Two years of practical maintenance experience on operating aircraft in the B1.1 category (not in the A1 category) is needed before applying for the extension. This experience need to be accumulated within the 10 years preceding the application.

The experience requirement will be reduced by 50% if the applicant has completed an approved Part-147 course relevant to the category extension according to Appendix IV of Part-66.

See Part-66.A.15.10, 66.A.25, 66.A.30 and related AMC/GM.

View

Was this helpful?

Vote up  6
Vote down  0

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?

According to 66.B.100(b), the competent authority shall verify that all required modules of Appendix I to Part-66 related to that new (sub)category sought are met. Credit can be granted as regards to the basic knowledge of the (sub)category for which the licence has been already issued.

This means that a comparison of the basic knowledge (gap analysis) will have to be done between the different (sub)categories. Such a comparison has not been yet done once and for all in Commission Regulation (EU) No 1321/2014 due to the different potential cases (wide diversity of (sub)categories).

Therefore such a comparison should be done by the Member State that has already issued the Part-66 licence, before the applicant is enrolled in such a “gap” basic knowledge course.

Please contact your competent authority, which may have already performed this comparison. Some competent authorities may have already posted such comparison(s) on their websites; however be sure that the comparison relevant to your case is acceptable to the competent authority who issued your licence.

In addition the applicant will have to comply with the additional experience requirements for the new (sub)category sought, as detailed in Appendix IV to Part-66.

View

Was this helpful?

Vote up  8
Vote down  18

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.

Regarding Part-66 Appendix III, point 5., “Type Examination Standard” does not apply to the examination performed as part of type training. This point only applies to those cases where type examination is performed as a substitute for type training, which means it is intended for the examinations conducted by (or on behalf of) the competent authority on those aircraft that do not require a type training (typically Group 2 and Group 3 aircraft according to Appendix I to the AMCs to Part-66). So, it is true that the examiners authorised by the competent authority shall not have been involved in the applicant's training. In all other cases AMC to Part-66 Appendix III applies, which means that the roles of  the assessor and the instructor may be combined for the practical elements, depending on the size of the organisation.

Regarding the roles of examiners and assessors, these are different functions (which does not prevent that one person can’t be authorised both as examiner and assessor). Normally, these functions should not be confused. The expression “The examination shall be oral, written or practical assessment based, or a combination thereof, …” applies only for Section 5, i.e. “Type Examination Standard”.

View

Was this helpful?

Vote up  50
Vote down  30

I have passed the aircraft type rating training (TRT) in an approved EASA Part-147 organisation, although I have not completed the basic knowledge training. Is this TRT valid for life? Would it be possible to endorse it on my Part-66 licence as soon as I get one?

Aircraft type rating training must have been started and be completed within the 3 years preceding the application for a type rating endorsement (Part-66, Appendix III, paragraph 1 refers).

It does not make sense to attend in the first instance a TRT course with the intent of getting this TRT later endorsed on the maintenance licence for two main reasons:

  • at the time the TRT is gained, the holder has no licence and it may take more than 3 years before the applicant is compliant with the basic knowledge (66.A.25) as well as the experience requirements (66.A.30). Therefore the applicant runs the risk to get its TRT certificate expired at the time he applies for the licence and the TRT endorsement; and
  • From an intellectual point of view, this is not logical to demonstrate maintenance competence on a specific aircraft type without having acquired the basic knowledge, skills and attitude related to the maintenance and the technologies used in aviation in general.

Legally speaking the situation is not forbidden. However be sure that you get your licence within the 3-years’ timeframe from the date you passed the TRT course.

View

Was this helpful?

Vote up  51
Vote down  20

I have attended a type training, may I immediately ask my authority to endorse it on my licence?

Yes, if the following conditions are met for the theoretical + practical parts of type training:

  • the course has been attended and the exams passed in a Part-147 approved training organisation,
  • or in another organisation, provided the course has been directly approved by the authority who issued the licence as per 66.B.130,
  • and for B1 and B2 licences, in case where the aircraft type is the first in a licence category or subcategory, an OJT training has been performed.
View

Was this helpful?

Vote up  33
Vote down  2

I hold a licence with a type rating and I wish to add the rating of a similar aircraft of the same manufacturer. For example: I have a type rating on Airbus A320 Series, and I wish to add the rating on A330 Series. Do I need a complete course?

If aircraft types of the same manufacturer have different type ratings as stated in Appendix I to AMC to Part-66, there is a gap of knowledge gap preventing the endorsement of the second aircraft type. E.g. the Airbus A330 (GE CF6) is a different rating to the Airbus A318/A319/A320/A321 (CFM56).

If the Airbus A318/A319/A320/A321 (CFM56) is previously endorsed or the criteria for endorsement are met (based on conversion or type training) the  Airbus A330 (GE CF6) can be endorsed (within the time limits) following either

  • a complete theoretical + practical  Airbus A330 (GE CF6) course,  or
  • a differences training course, theoretical and practical for Airbus A330 (GE CF6) compared to  Airbus A318 (CFM56) (and/or A319/A320/A321) as described in Appendix III point 1(c).

Those training courses may either be provided by a Part-147 training organisation or by the competent authority.

Remark: A Part-147 organisation difference training is not required for variants within the same aircraft type rating, for example: from A320 to A321. Nevertheless, some training to cover the differences may be necessary. This may be provided by an approved maintenance organisation, before issuing the certifying staff authorisation, (see AMC to Paragraph 1(c) of Appendix III to Part-66 ‘Aircraft Type Training and Examination Standard. On-the-Job Training’).

View

Was this helpful?

Vote up  0
Vote down  1

I just got an empty Part-66 licence. I plan now to get type ratings. Are 2 weeks practical training sufficient?

As per the new Regulation (EC) No. 1149/2011, the practical element of training is no longer a question of time. The duration of the practical training should be adequate in order to complete the contents required by paragraph 3.2 of Appendix III to Part-66.

For aeroplanes with a MTOM equal or above 30.000 kg the duration for the practical element of a type rating training course should not be less than two weeks.

In addition, for B1 and B2 licences, where the aircraft is the first in a licence category or subcategory, an on the job(OJT) training shall be performed.

View

Was this helpful?

Vote up  24
Vote down  6

The Appendix III of Part-66 states that a type training course shall be started and finished within 3 years before the application for a type rating, is this still valid if I started the course before 1 August 2012?

Type training courses started and finished before 01 Aug 2012 can be used for rating endorsement application until 31 July 2015.

Any theoretical type training course finished after 01 Aug 2012 can be used for rating endorsement application until 3 years after they were started (even in the case where they were started before 01 Aug 2012).

Any practical type training course finished after 01 Aug 2012 can be used for rating endorsement application until 3 years after they were started (even in the case where they were started before 01 Aug 2012).

View

Was this helpful?

Vote up  23
Vote down  11

Is it mandatory to go to a Part-147 approved training organisation to get type training? Can we do this training in a Part-145 approved organisation or at the aircraft manufacturer?

Only approved Part-147 organisations are entitled to conduct type training courses in accordance with Article 6 of the Commission Regulation (EU) No 1321/2014. However, according to Appendix III to Part-66, other than Part-147 organisation (including Part-145 maintenance organisations and manufacturers) can be approved by their competent authorities to provide theoretical element (theoretical training and examination) and/or practical element (practical training and assessment) of aircraft type training. This so called “direct” approval may be given by the competent authority in accordance with 66.B.130 provided:

  • This is a one-time approval on a case-by-case basis for a single course or a predefined group of courses i.e. Part-145 approved maintenance organisation cannot receive a permanent approval for aircraft type training.
  • The course and the assessment complies with the same standard valid for approved Part-147 organisations; this standard is described in paragraph 1 to 4 of Appendix III to Part-66.
  • No Part-147 Certificate of Recognition can be issued for the purpose of the mutual recognition[1] between Member States. However, an appropriate training certificates can be issued after successful completion of both elements.

Directly approved aircraft type training course is only valid for Part-66 AML type rating endorsement by that Member State, which means it cannot be used for aircraft type endorsement by other Member States (no mutual recognition of the certificate), unless this other competent authority has approved the course as well.

View

Was this helpful?

Vote up  18
Vote down  7

OJT (On the Job Training) for a Part-66 licence

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  type training.

Completeness of the OJT.

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.

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 or M.A. Subpart F with A rating

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.

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)

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.)

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 Exposition Manual (chapter 3.15) or “one-off” direct approval

Reference: Appendix III 1(b); Part-147

Reference: AMC 145.A.70 (a)

View

Was this helpful?

Vote up  33
Vote down  7

(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.

View

Was this helpful?

Vote up  14
Vote down  6

Tasks listed in Appendix II of Part-66 for an OJT are not suited to large aircraft. Shall we select the OJT tasks only from this list?

Not only, because it is required that:

  • the tasks for an OJT must be representative of the aircraft: this means that the tasks listed in Appendix II which are representative of the aircraft or another model in the type rating should be kept and those not representative be disregarded,
  • some tasks should be selected from each paragraph of the Appendix II list: this means that it is not necessary to perform exactly 50% in each ATA chapter,
  • new tasks more representative of the type of aircraft may be added by the maintenance organisation,
  • the OJT tasks should be selected because of their frequency, safety, novelty: tasks selected among those frequently carried out by the organisation on this type or more related to safety should be deleted.
View

Was this helpful?

Vote up  21
Vote down  4

How tasks for OJT shall be selected for different licences?

The AMC states that the tasks are representative of the licence (sub)category applied for. This means that:

  • the tasks should identify whether they relate to a B1.1, B1.3 licence … or to a B2,
  • and be adapted to the privilege of each licence category / subcategory as defined in 66.A.20(a)3:
    • for a B1 licence: aircraft structure, powerplant and mechanical and electrical systems + work on avionics system with simple test but not including troubleshooting,
    • and those related to a B2: avionics, aircraft electrical system tasks and avionics/electrical tasks within mechanical and powerplant systems.
View

Was this helpful?

Vote up  12
Vote down  7

Since the OJT is intended for the first aircraft type endorsement within a given licence (sub)category, does this mean that it can be performed on different aircraft types typical for that (sub)category?

OJT shall be performed on the aircraft type for which the applicant is seeking type endorsement. The objective of the OJT is to gain the required competence and experience in performing safe maintenance on that particular aircraft type.

However, a certain number of tasks may be performed on other aircraft type(s) (typically from the same manufacturer), only in the cases where such tasks are very similar to the tasks applicable to the aircraft type for which the candidate seeks the type endorsement. The AMC to section 6. of Appendix III to Part-66 states: “Tasks should be selected among those applicable to type of aircraft and licence (sub)category applied for.” Tasks applicable to the aircraft type may be found also on other aircraft types, perhaps not many, but some may fulfil the requirement. A good example would be same engine types installed on different aircraft types (i.e. CFM56 installed on A320 Family and B737). The location of LRUs, oil servicing, IDG, generator, filter change, engine standard practices, etc., those tasks often do not depend on the specific aircraft type (even could be performed off-wing or on spare engine), except the tasks belonging to the airframe - engine interface. The similar can also be applied for the same type of APU installed on different aircraft types or a limited number of other components/systems. Consequently, this may be acceptable, if properly justified to the competent authority within the MOE Chapter 3.15. This flexibility provision is applicable for a limited number of tasks and should not be used to conduct the entire OJT on other aircraft type(s) showing similarities.

View

Was this helpful?

Vote up  13
Vote down  12

What should be the content of the OJT procedure in MOE chapter 3.15?

As agreed during the Standardisation Meeting with the competent authorities, as a minimum, the OJT procedure should describe the following elements:

  • Content of the OJT: the list of tasks that should be performed during the OJT or a list of generic tasks and the process how to develop a list of particular tasks out of this list of generic tasks,
  • Qualifications of the assessor and supervisors performing the OJT,
  • OJT logbook/worksheets format and content,
  • OJT compliance report format and content
  • Production planning for the implementation of OJT (how to plan the tasks),
  • Supervision process and the assessment process, what to do if the assessment is not positive,
  • Safe release to service of the aircraft after OJT.

Note: AMC to Section 6. of Appendix III to Part-66 should be used when defining the content of the procedure.

View

Was this helpful?

Vote up  14
Vote down  8

I work in a maintenance organisation approved by the competent authority of a country different from the one who issued my Part-66 licence. An OJT programme via MOE chapter 3.15 has been approved by the competent authority of my maintenance organisation. However, my licensing authority refuses to accept the OJT from the organisation I’m working for. Why? What shall I do?

Please review the extracted requirements here below from Part-66 Appendix III, Section 6:

  • ‘On-the-Job Training (OJT) shall be approved by the competent authority who has issued the licence.’
  • ‘It shall be conducted at and under the control of a maintenance organisation appropriately approved for the maintenance of the particular aircraft type’.
  • ‘OJT shall cover a cross section of tasks acceptable to the competent authority’.
  • ‘In order to facilitate the verification by the competent authority, demonstration of the OJT shall consist of:
    • detailed worksheets/logbook and
    • (ii) a compliance report demonstrating how the OJT meets the requirement of this Part.’

Since the procedure in MOE is approved by the competent authority of the maintenance organisation, it can only be used when the licensing authority is the same as the competent authority of the maintenance organisation. In other cases, the licensing authority may accept such OJT after assessing and approving the programme, which should usually be done prior to starting the OJT. This is described in AMC 66.B.115(c) states that “in the case where the licensing competent authority is different from the competent authority of the maintenance organisation which provides the OJT, your licensing authority may take into consideration the fact that the maintenance organisation has the OJT programme already accepted by their own competent authority (through chapter 3.15 of the MOE, as described in AMC 145.A.70(a))”.

Since your competent authority is responsible for the issue and extension of your licence, please follow the instruction of your competent authority and try to find a solution based on the above AMC.

View

Was this helpful?

Vote up  25
Vote down  9

How can I carry out my OJT in a Part-145 approved maintenance organisation (AMO) whose principal place of business is located outside the EASA Member States?

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 (or M.A. Subpart F) with A rating 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 AMOs, 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 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. 

View

Was this helpful?

Vote up  10
Vote down  2

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)?

By default, a category B3 licence is included in a category B1.2 licence because the basic knowledge requirements (66.A.25(a)) and the basic experience requirement (66.A.30) for a B3 licence are covered by the similar requirements of a B1.2 licence.

Provided that the qualification requirements are fulfilled, the B1.2 licence holder can release maintenance tasks performed on piston-engine non-pressurised aeroplanes of 2000 kg MTOM and below.

In particular the B1.2 licence holder would have to meet 66.A.20(b), which means that:

  • the applicable requirements of Part-M and/or Part-145 will be complied; and
  • in the preceding two-year period he/she has 6 months of maintenance experience in accordance with the privileges granted by the aircraft maintenance licence or; met the provision for the issue of the appropriate privileges; and
  • he/she has the adequate competence to certify maintenance on the corresponding aircraft; and
  • he/she is able to read, write and communicate to an understandable level in the language(s) in which the technical documentation and procedures necessary to support the issue of the certificate of release to service are written.

AMC 66.A.20(b)  and GM 66.A.20(b)  gives further explanations on the 6-months maintenance experience in the last 2 years, including demonstration of experience on at least one aircraft type per aircraft structure (metal, composite or wood).1 

1 - “Aeroplane” does not include “helicopter”.
View

Was this helpful?

Vote up  27
Vote down  15

Can I get a Part-66 licence with Annex II aircraft endorsed on my licence?

Type ratings should be endorsed on the Part-66 licence in accordance with the list of type ratings shown in the ED Decision posted under the Aircraft type ratings for Part-66 aircraft maintenance licence page.

This list does not contain any Annex II aircraft as these are out of the scope of Basic Regulation according to subparagraph 4 of Article 4 on the maintenance field.
However, a Part-66 licence includes a page whose title is: ‘Annex to EASA Form 26’ and this page is dedicated to national privileges. When an aircraft is under the remit of the Member State, then such aircraft may be endorsed under these provisions. This is typically the case of Annex II aircraft.

View

Was this helpful?

Vote up  11
Vote down  2

Is there a requirement to have 6 months’ experience every 2 years to maintain the validity of the Part-66 licence?

No, the validity of the Part-66 licence is not affected by recent experience. The requirement of 6 months’ experience within the preceding 2 years ensures that privileges are exercised by certifying staff with sufficient recent experience.

If you do not meet the experience requirement anymore, you lose your rights to exercise your privileges of certifying staff or support staff. The licence itself is valid 5 years from the last renewal. Only the certification privileges are affected by the “recency” of experience.

To regain your experience, you may:

  • either continue to accumulate maintenance experience until you gain the missing time required, or
  • meet the provisions for the issue of appropriate privileges, which means:
    • going to a type-training course again, including OJT as necessary, or
    • when the aircraft does not require an individual training (aircraft belonging in Group 2, 3 or 4), pass a type-examination, including practical assessment (see GM 66.A.20(b)2).

Neither a short period of job training session nor an aircraft type refresher training are acceptable. 
Demonstration of experience should be made on the particular or similar aircraft and the definition of a ‘similar’ aircraft is provided in the AMC to 66.A.20(b)2.

View

Was this helpful?

Vote up  1
Vote down  0

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)?

The list of typical tasks to be carried out by a category A certifying staff at line shown in the AMC include a line r. stating: “Any other task agreed by the competent authority as a simple task for a particular aircraft type. This may include defect deferment when all the following conditions are met:

  • there is no need for troubleshooting; and
  • the task is in the MEL, and
  • the maintenance action required by the MEL is agreed by the competent authority to be simple.

When these conditions are met, your authority may allow other tasks to be carried out under AMC 145.A.30g.

View

Was this helpful?

Vote up  20
Vote down  11

Part-147

Others

Shall a Part-147 approved organisation have a mandatory occurrence reporting system according to (EU) No.376/2014?

Article 4 of Regulation (EU) No. 376/2014 defines the persons and organisations obliged to report occurrences under the “mandatory reporting system”. Personnel working at/for organisations approved in accordance with EASA Part 147 are not listed in paragraph 6 of article 4, therefore such organisations are not required to implement mandatory/ voluntary reporting systems according to Regulation (EU) No. 376/2014. This does not prevent any organisation or person involved in aviation activities, including maintenance training activities, to report any safety occurrence or other safety information they consider relevant.

Such reports would be to the voluntary reporting system to be established by all competent authorities according to Article 5.2 of Regulation (EU) No. 376/2014.

Typically a Part- 147 approved training organisation having implemented an Safety Management System (SMS) on a voluntary basis would have such a voluntary occurrence reporting system.

The European Commission (EC) published Guidance Material  for Regulation EU No. 376/2014. Paragraph 3.3 further elaborates on the organisations affected by that regulation.

An online service developed by the EC allows organisations and individuals to report aviation safety occurrences to aviation authorities.

View

Was this helpful?

Vote up  10
Vote down  3

Part-147 approved organisations can also give courses outside the scope of Part-66. Can these courses be certified? (e.g. continuation training for the purpose of the certifying staff privileges as required by 145.A.35, task training, NDT, engine run, HF, SMS, etc.)

Courses outside the scope of Part-66 cannot be part of the Approval Schedule of the approved Part-147 organisation. This does not prevent a training organisation to provide such courses. The scope, content and the delivery methods of these courses will not be reviewed by the Agency or the EASA Member States, as part of the audit scope of the Part-147 organisation. However, when Part-M or Part-145 requires the staff to be trained, the appropriateness of such training being delivered would be assessed during the audits of these particular organisations.

View

Was this helpful?

Vote up  24
Vote down  6

How can I become an EASA aircraft maintenance instructor?

Part-147, in particular, 147.A.105 (f), state that the experience and qualifications of instructors, knowledge examiners and practical assessors shall be established in accordance with criteria published or in accordance with a procedure and to a standard agreed by the competent authority. There are no additional requirements or guidance published in EASA rules regarding the experience and qualification of instructors, except that it is recommended that potential instructors be trained in instructional techniques.

The eligibility of candidates to a permanent or temporary (contracted independent) instructor’s position must be assessed in regards to the minimum qualifications defined by the concerned Approved Part 147 Training Organisation. The Organisation’s procedures should detail these minimum qualifications and associated eligibility criteria in terms of technical knowledge, pedagogical and instructional skills and working experience.

EASA does not issue Instructor licences or equivalent, and permanent or contracted instructors can only exercise instruction privileges through the approval of a Training Organisation. Instructors are nominated by the approved organisation, which keep detailed records of their qualifications and are audited by the authority. Their authorised scope of activity is then stated on Terms of Reference provided to the instructors, as well as on the instructor/ examiners/ assessors approved list.

For any further questions, we advise you to contact the training organisation Quality Assurance Dept. and/ or the Competent Authority (the one who granted the approval), in order to enquire about the possibility to be nominated as an instructor.

View

Was this helpful?

Vote up  5
Vote down  2

Should the Part-147 organisation’s quality system be audited?

147.A.130(b) states that the approved Part-147 organisation shall establish a quality system including:

  1. an independent audit function to monitor training standards, the integrity of knowledge examinations and practical assessments, compliance with and adequacy of the procedures, and
  2. a feedback system of audit findings to the person(s) and ultimately to the accountable manager referred to in 147.A.105(a) to ensure, as necessary, corrective action.

This means that the quality system itself should be independently audited. The competent authority cannot perform this function on behalf of the organisation.

Within its approved procedures, the organisation has to monitor the quality system’s procedures. This implies that quality system monitoring itself must be subject to internal audits:

  • No conflict of interest is allowed - it is not permitted that such a function be performed by quality system’s staff;
  • This can be also outsourced;
  • The right level of the auditor(s)’ position within the organisation shall be met in order to assure the objective of 147.A.130 (b)2. (e.g. conflict of hierarchy, which could hinder an efficient and transparent report to the accountable manager).

In addition, the audit programme/plan needs to reflect this regulatory aspect.

The EASA Flight Standard Directorate consistently applies that policy during their standardisation visits.

View

Was this helpful?

Vote up  12
Vote down  7

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?

No, a Part-147 approval can only be granted to an organisation which plans to conduct training on all the modules related to a (sub)category of an aircraft maintenance licence, so that a full understanding of the training needs, interfaces and examination relative to that (sub)category of licence is achieved.

However, some modules may be sub-contracted as mentioned in 147.A.145(d).

It does not mean that the Part-147 organisation is not allowed to conduct courses on just one module. In particular, in the case of limitations resulting from the conversion process, limitations can be lifted through the teaching and/or examination of one module or a part of a module.

View

Was this helpful?

Vote up  30
Vote down  3

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 B1 or B2:

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 2 years of maintenance experience.

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 3 years of experience (if recognised as skilled worker) or 5 years.

  • 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 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 2 years needed) 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 – 3 years). Standard 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.

View

Was this helpful?

Vote up  34
Vote down  9

Is it possible to grant a Part-147 approval to a training organisation which intend to conduct only basic knowledge examinations?

No, a Part-147 approval can only be granted to an organisation which can prove its capability to conduct training and examinations on a complete syllabus of at least one (sub)category of the Part-66 licence. Only in the case the organisation holds the approval for the complete basic training course, it may conduct basic examinations not being an integral part of the approved basic training course.

View

Was this helpful?

Vote up  15
Vote down  2

Is it possible to grant a Part-147 approval to an organisation applying only for basic knowledge training?

Yes, in such case Form 148 shall be used as template for the Certificate of Recognition, which specifies “Basic training course” or “Basic examination”. In the particular case where all modules are not conducted, (see next questions) the certificate shall state only “Basic examination” and the modules conducted be mentioned on the certificate including the date(s) of the examination(s).

Reference: 147.A.145

View

Was this helpful?

Vote up  11
Vote down  4

Part-147 approved organisations have the privilege to carry out basic examinations on behalf of the competent authority. Does this imply that the said authority has to supply or approve examination questions?

No, the competent authority does not have to supply examination questions. However, as part of the oversight, the authority must sample check and review the organisations' question data bank and the examination process.

View

Was this helpful?

Vote up  11
Vote down  4

Type training

Is it possible to perform aircraft type training in two different organisations? Can I do my practical portion of the type training in a Part-145 organisation?

Only a Part-147 organisation has the privilege (if approved by its competent authority) to provide aircraft type training courses. This comprises both the theoretical and practical element of the aircraft type training, including the related examinations and assessments. This means that the practical element of the aircraft type training shall be completed in a Part-147 organisation.

However, the aircraft type training may be conducted physically in a Part-145 organisation under the control (and as a part of the approval) of a Part-147 organisation issuing the Certificate of Recognition. It is not the privilege of the Part-145 organisation to conduct aircraft type training courses on its own.

In addition, the theoretical and practical element of the aircraft type training can be conducted by two different approved Part-147 organisations. The competent authority endorsing the type rating on the license should be convinced that the interfaces have been correctly addressed before proceeding thereof (66.B.115(b) refers).

In the special case where the aircraft type course is directly approved by the competent authority in accordance with the procedure 66.B.130 (i.e. only on a case by case basis – special authorization not granted for long term periods), the training can be conducted outside the scope of a Part-147 organisation. As a consequence, the certificate issued is not mutually recognized between Member States, which means it can only be used for aircraft type endorsement by the licensing authority who issued that direct approval.

 

View

Was this helpful?

Vote up  14
Vote down  5

How should the 50% of tasks required for practical training be selected? Should it be 50% of tasks as per glossary (e.g. LOC, FOT, SGH, R/I, etc.)?

The selection of 50% of tasks cannot be selected according to the glossary. Paragraph 3.2 of Appendix III to Part-66 clearly states that ‘the tasks selected shall be representative of the aircraft and systems both in complexity and diversity. In addition, the practical training should particularly address the tasks which cannot be explained by theoretical training only. While relatively simple tasks may be included, other more complex tasks shall also be incorporated and completed as appropriate to the aircraft type.

Regarding the way to read the table in paragraph 3.2, the lines aims at covering the main systems so that no line relevant to the particular aircraft type should be omitted in the selection. Inside each line applicable to the aircraft type, half or more of the crosses can be selected. From a learning point of view, selecting 2 simple tasks as LOC and SGH would not be “representative”, while selecting LOC and TS, for example, would be much more appropriate.

When selecting the tasks, the usage of filtering method based on the criteria similar to that described in AMC to paragraph 3.1(d) of Appendix III to Part-66, point 5 f) is recommended.

View

Was this helpful?

Vote up  12
Vote down  13

What is the minimum duration of the practical element of the aircraft type training?

The duration of the practical training should ensure that the content of training required by paragraph 3.2 of Appendix III to Part-66 is completed. However, for aeroplanes with a MTOM equal or above 30000 kg, AMC to paragraph 1(b) of Appendix III to Part-66 recommends the duration of the practical element of a type rating training course be not less than two weeks, unless a shorter duration meeting the objectives of the training and taking into account pedagogical aspects (maximum duration per day) is justified to the competent authority. This means that the duration of the a/c type practical training is not the main driver as justified by the status of that AMC. According to point 3.2 (b) Appendix III to Part-66 (having the status of requirement), the duration should be based on the content sufficiently representative in diversity and complexity in order to gain the needed competence.

View

Was this helpful?

Vote up  9
Vote down  8

Examination

Can an examination be limited to some modules only, or one module only or part of a module only?

As mentioned in the previous question, for some particular cases, the basic training need to be conducted and the relevant examination to be passed on some modules only or one module or part of a module (this is typically the case where the holder of a licence applies for removing some limitations mentioned in his/her licence).

However, the Part-147 organisation should be capable of conducting the full course relative to the (sub)category sought, so that they can run the examination.

View

Was this helpful?

Vote up  11
Vote down  3

Should examiners be specialists in the subjects, or can they be responsible for the proper conduct of the examination without being responsible for the content?

“Examiner” should be here understood as “invigilator” (i.e. the personnel responsible for merely running the examination).

The examiners (invigilators) are not required to be experts in the subjects examined when relative to the MCQs in accordance with Appendix II to Part-66. However, the assessment  of essay questions as part of the basic knowledge has to be conducted by knowledgeable personnel with the help of a standard reply. Eventually, the invigilators must be trained to the examination process.

Examiners should demonstrate a clear understanding of the examination standard required by Part-66 and have a responsible attitude to the conduct of examinations such that the highest integrity is ensured. (GM 147.A.105(g)).

Regarding the type training examination and assessment standard as well as type examination standard as described in Part-66, Appendix III, paragraphs 4 and 5, the theoretical element examination can follow the same principle as above; however, for the practical element assessment, the examiner(s) must be appropriately qualified. Further provisions are available in Appendix III to AMC to Part-66.

View

Was this helpful?

Vote up  26
Vote down  5

What is the maximum number of students attending the examination?

147.A.100(b) defines the facility requirements for the instructions of theory and the conduct of knowledge examinations. Point 1 deals with the facility requirement for knowledge training whereby the number of students shall not exceed 28. Point 2  defines the facility requirements for the examination purposes, where the maximum number of students attending the knowledge examination is not limited. The number of students attending the knowledge examination is indirectly limited only by the size, layout and arrangement of the accommodation in order to fulfil the following requirements:

  •  … no student can read the paperwork or computer screen of any other student from his/her position during examinations (147.A.100(b)2), and
  • Examination candidates shall be separated from each other so that they cannot read each other’s examination papers. (66.B.200(h)).

Consequently, as long as the facility and examination standard as well as the integrity of the examination can be ensured, the number of candidates attending the examination may not be limited. In case of a larger number of candidates, two or more examiners may be used to ensure the integrity of the examination, such as separation of the candidates, no potential cheating, no speaking to each other, only examination paper on the table, no examination paper removed from the room, etc.

View

Was this helpful?

Vote up  19
Vote down  2
Back to top

Air Operations

Air Operations - General

Will the new rules be available in all official languages of the European Union and where are the rules published?

Reference: Regulation (EU) No 1178/2011 and its amendments, Regulation (EU) No 965/2012 and its amendments, related EASA Decisions (AMC/GM/CS)

The new requirements (on aircrew, air operations and third country operators) consist of:

  1. a Cover Regulation,
  2. Annexes containing Implementing Rules,
  3. Acceptable Means of Compliance (AMC) and Guidance Material (GM),
  4. Certification Specifications (e.g. for the qualification of flight simulation training devices, or on flight time limitations).

They are published in the Official Journal of the European Union.

Commission Regulation (EU) No 1178/2011 containing the first four annexes of the Aircrew Regulation was published in the Official Journal on 25 November 2011.

The remaining three annexes of the Aircrew Regulation were published in the Official Journal as Commission Regulation (EU) No 290/2012 on 5 April 2012.

Commission Regulation (EU) No 965/2012 on air operations and applicable to commercial air transport operations with aeroplanes and helicopters was published in the Official Journal on 25 October 2012.

Commission Regulation (EU) 800/2013 amending Regulation (EU) No 965/2012 and applicable to non-commercial operations with complex motor-powered aircraft (Part NCC) and other-than-complex motor-powered aircraft (Part NCO) was published in the Official Journal on 24 August 2013. The date of applicability is 25 August 2013. It also amends Regulation (EU) 965/2013 in its already published Annexes accordingly.

The Official Journal is published in all the official languages of the EU.

Acceptable Means of Compliance (AMC), Guidance Material (GM) and Certification Specifications (CS) are published on the Agency website, as Agency Decisions. As these need to take into account any changes made to the Cover Regulation and Implementing Rules by the EASA Committee, European Parliament and Council, the Decisions are published shortly after the date when their corresponding regulations have been published in the Official Journal. These are available in English only.

View

Was this helpful?

Vote up  7
Vote down  1

What is the status of documents published during the EASA Rulemaking process such as Notice of Proposed Amendment (NPA) or Comment Response Document (CRD)? Can they be used if there is no EASA rule available?

Reference: Regulation (EC) No 216/2008

NPAs and CRDs are part of the Agency's rulemaking process, to inform and consult stakeholders on possible rule changes or newly developed rules. The proposed rules are obviously not binding and still subject to change, either during the EASA rulemaking process or the Commission's comitology process. While a NPA and CRD may give a broad indication on how the future rule could look like, the Agency generally does not recommend using it before the final rules are published in the Official Journal of the European Union.

View

Was this helpful?

Vote up  7
Vote down  2

How can alternative means of compliance to the AMC published by the Agency be used by NAAs, operators and approved training organisations across the EU?

Reference: Regulation (EU) No 290/2012 on Aircrew (ARA.GEN.120); Decision AMC/GM to Part ARA (AMC1 ARA.GEN.120(d)(3), GM1 ARA.GEN.120); Regulation (EU) No 965/2012 on Air Operations (ARO.GEN.120); Decision AMC/GM to Part ARO (AMC1 ARO.GEN.120(d)(3), GM1 ARO.GEN.120)

The only means of compliance to the Aircrew/Air OPS Regulations that all organisations can use across the EU are the AMC as published by the Agency. For alternative means of compliance, the following scenarios are foreseen:

  1. an alternative means of compliance approved for an individual organisation may be used by another organisation, but that organisation must also apply for approval to use such alternative means of compliance;
  2. an alternative means of compliance issued by the competent authority (e.g. NAA) may be used by all organisations for which that authority is responsible.

Whenever the competent authority accepts an alternative means of compliance proposed by an organisation, it must notify the Agency and inform all other Member States. However, each Member State may decide how to deal with this information. This is explained in:

Regulation (EU) No 290/2012 on Aircrew:

ARA.GEN.120 MEANS OF COMPLIANCE

“(d) The competent authority shall evaluate all alternative means of compliance proposed by an organisation in accordance with ORA.GEN.120 by analysing the documentation provided and, if considered necessary, conducting an inspection of the organisation.

When the competent authority finds that the alternative means of compliance are in accordance with the Implementing Rules, it shall without undue delay:

(1) notify the applicant that the alternative means of compliance may be implemented and, if applicable, amend the approval or certificate of the applicant accordingly; and
(2) notify the Agency of their content, including copies of all relevant documentation;
(3) inform other MS about alternative means of compliance that were accepted.

(e) When the competent authority itself uses alternative means of compliance to achieve compliance with Regulation (EC) No 216/2008 and its Implementing Rules it shall:

(1) make them available to all organisations and persons under its oversight; and
(2) without undue delay notify the Agency.
The competent authority shall provide the Agency with a full description of the alternative means of compliance, including any revisions to procedures that may be relevant, as well as an assessment demonstrating that the Implementing Rules are met.”

AMC1 ARA.GEN.120(d)(3):

“The information to be provided to other Member States following approval of an alternative means of compliance should contain a reference to the Acceptable Means of Compliance (AMC) to which such means of compliance provides an alternative, as well as a reference to the corresponding Implementing Rule, indicating as applicable the subparagraph(s) covered by the alternative means of compliance.”

GM1 ARA.GEN.120 explains that alternative means of compliance are valid for an individual organisation:

“Alternative means of compliance used by a competent authority or by organisations under its oversight may be used by other competent authorities or organisations only if processed again in accordance with ARA.GEN.120 (d) and (e).”

When the Agency finds that an alternative means of compliance of which it has been notified has value to be issued as an Agency AMC, this alternative means of compliance will be fed into the Rulemaking process. On completion of the rulemaking process, the means of compliance will be published as AMC.

AMC & GM to Part ARA are available here.

Regulation (EU) No 965/2012 on Air Operations:

ARO.GEN.120:

“(d) The competent authority shall evaluate all alternative means of compliance proposed by an organisation in accordance with ORO.GEN.120 (b) by analysing the documentation provided and, if considered necessary, conducting an inspection of the organisation.
When the competent authority finds that the alternative means of compliance are in accordance with the Implementing Rules, it shall without undue delay:

(1) notify the applicant that the alternative means of compliance may be implemented and, if applicable, amend the approval or certificate of the applicant accordingly; and
(2) notify the Agency of their content, including copies of all relevant documentation.
(3) inform other Member States about alternative means of compliance that were accepted.

(e) When the competent authority itself uses alternative means of compliance to achieve compliance with Regulation (EC) No 216/2008 and its Implementing Rules it shall:

(1) make them available to all organisations and persons under its oversight; and
(2) without undue delay notify the Agency.

The competent authority shall provide the Agency with a full description of the alternative means of compliance, including any revisions to procedures that may be relevant, as well as an assessment demonstrating that the Implementing Rules are met.”

AMC1 ARO.GEN.120(D)(3): MEANS OF COMPLIANCE

“GENERAL
The information to be provided to other Member States following approval of an alternative means of compliance should contain a reference to the Acceptable Means of Compliance (AMC) to which such means of compliance provides an alternative, as well as a reference to the corresponding Implementing Rule, indicating as applicable the subparagraph(s) covered by the alternative means of compliance.”

GM1 ARO.GEN.120 MEANS OF COMPLIANCE

“GENERAL
Alternative means of compliance used by a competent authority or by organisations under its oversight may be used by other competent authorities or organisations only if processed again in accordance with ARO.GEN.120 (d) and (e).”

In the Information on Alternative Means of Compliance notified to the Agency page you can find a list of all the notifications sent by the Member States to EASA with the alternative means of compliance that they adopted.

View

Was this helpful?

Vote up  7
Vote down  3

What is the definition of ‘cabin crew member’? Does the definition of Aircrew include cabin crew members?

Commission Regulation (EU) No 290/2012 on Aircrew gives the following definitions:

Article 1 (2)(11) defines ‘cabin crew member’ as follows:

(11) “Cabin crew member” means an appropriately qualified crew member, other than a flight crew or technical crew member, who is assigned by an operator to perform duties related to the safety of passengers and flight during operations;

Article 1 (2)(12) defines Aircrew as follows:

(12) “Aircrew” means flight crew and cabin crew; To conclude, the definition of aircrew includes cabin crew member.

View

Was this helpful?

Vote up  24
Vote down  5

Is there a consolidated version of the EASA decisions containing AMC and GM?

Yes, in the list of pdf documents on the Acceptable Means of Compliance and Guidance Material page, please select the documents entitled 'Supplementary document to ED Decision.

The consolidated version shows the different amendments in a single document and makes it much easier to find the appropriate AMC and GM for your type of operation.

View

Was this helpful?

Vote up  21
Vote down  14

What happens to existing EU-OPS (aeroplane) AOCs? Are they still valid in the new system? Will EASA issue Air Operator Certificates in the future?

Reference: Regulation (EU) No 965/2012 on Air Operations

As stated in Article 7.1 of the Regulation (EU) No 965/2012 on Air Operations, EU-OPS (aeroplane) AOCs issued by a Member State before the Regulation applies shall be deemed to have been issued in accordance with this Regulation. This means that an operator will not have to re-apply for an AOC.

However, all existing AOCs issued before the entry into force of this Regulation will have to be replaced by AOCs corresponding to the new format (Appendix I to Part ARO) no later than 28 October 2014. Before the new AOC document can be issued, operators will have to adapt their management system, training programmes, procedures and manuals accordingly. More detailed information on how this transition process is managed is available from the national aviation authority that issued the AOC.

EASA will not issue AOCs. New AOCs will continue to be issued by National Aviation Authorities (the competent authority for this scope) in compliance with the requirements for organisations (Part ORO) and authorities (Part ARO).

View

Was this helpful?

Vote up  12
Vote down  2

There are four different aircraft categories in the rules - aeroplanes, helicopters, sailplanes, balloons. How can I identify which rules apply to a balloon pilot for example?

Reference: Regulation (EU) No 965/2012 on Air Operations

Where rules apply only to a specific category of aircraft, this has been indicated in the title. Within Subpart IDE (instruments, data and equipment), sections for each aircraft category have been created, so there the distinction is easy to make. Where no distinction is made in the rule title or section, the rule will apply to all aircraft categories.

View

Was this helpful?

Vote up  9
Vote down  24

The definition of commercial operation according to Regulation (EC) No 216/2008 Article 3 (Definitions) (i) is as follows: “commercial operation” shall mean 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 a customer, where the latter has no control over the operator.” In this context, what does the term “control” actually mean?

Reference: Regulation (EC) No 216/2008 (‘the Basic Regulation’)

The legislator has not further specified the term “control”. It is therefore EASA’s view that it should be understood in a wider sense, i.e. the term is not limited to operational control. In this sense, control could for example also encompass financial control, control of management decisions etc. This notion of the definition is for example particularly valid for managed operations or fractional ownership. These are operations where an aircraft is owned by one or several persons who contract a management company to manage operations and continuing airworthiness. It then depends on the specific contract between the owner(s) and the management company how much control the owner(s) still have over the operation.

View

Was this helpful?

Vote up  12
Vote down  35

Would there be a restriction that requires baby bassinets to be removed and stowed during in-flight turbulent weather conditions? Where is it documented?

Reference: CS-25 (Large Aeroplanes)

Baby bassinets are currently included in a certification process of the particular aircraft in which they will be installed; baby bassinets are not certified as a separate device and they are not certified for taxi, take-off, landing and turbulent weather conditions. Placards advising on their stowage 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 in place on the baby bassinet itself.

Because of the standard fixation of the unit, they are not stable during turbulence, they may swing up and down, and therefore they must be stowed during turbulence.

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. The applicable reference paragraph is CS 25.1301, 25.1541. There is no specific mention of baby bassinets, however, equipment installed in an aircraft must meet the applicable requirements of the certification basis, the equipment specifications (if available) or aircraft manufacturer specifications (if available), or NAA requirements applicable to the operation of the aircraft.

For any questions on certification matters, do not hesitate to contact EASA Certification directorate.

View

Was this helpful?

Vote up  5
Vote down  7

What is the 'Basic Regulation'?

Reference: Regulation (EC) No 216/2008

The 'Basic Regulation' (BR) designates Regulation (EC) No 216/2008 of the European Parliament and of the Council of 20 February 2008 on common rules in the field of civil aviation and establishing a European Aviation Safety Agency, and repealing Council Directive 91/670/EEC, Regulation (EC) No 1592/2002 and Directive 2004/36/EC, as amended by Commission Regulation (EC) No 690/2009 and Regulation (EC) No 1108/2009 of the European Parliament and of the Council of 21 October 2009. A consolidated version of the Basic Regulation can be found here.

Under the EU legal order, the Basic Regulation has general application. It is binding in its entirety and directly applicable in all Member States. The main objective of the BR is to “establish and maintain a high uniform level of civil aviation safety in Europe” - Article 2 (1). Additional objectives are, among others, to ensure a high uniform level of environmental protection, to facilitate the free movement of goods, persons and services and to provide a level playing field for all actors in the internal aviation market” - Article 2 (2) (a), (b) and (f). One of the means to attain such objectives is “the preparation, adoption and uniform application of all necessary acts” - Article 2 (3) (a).

For that purpose, the BR conferred to the European Commission the power to adopt implementing rules which will detail how to comply with the essential requirements of the BR and will regulate the subject matters included in the its scope: airworthiness of aircraft, environmental protection, pilots, air operations, aerodromes, ATM/ANS, Air Traffic Controllers and aircraft used by third country operators into, within or out of the Community - see, among others, item 38 of the preamble to the BR.

One of EASA's (the Agency) tasks is to assist the Commission in the adoption of implementing rules, under Articles 18(a) and 19 BR.

Therefore, Regulation (EC) No 216/2008, as last amended, has been termed as the Basic Regulation in the Agency's documentation. The implementing rules proposed by the Agency take the form of Opinions addressed to the Commission. Once approved under the Comitology procedure, such implementing rules are published as Commission Regulations and this term appears in their titles.

Further FAQs on the Basic Regulation are available here.

View

Was this helpful?

Vote up  36
Vote down  10

What are the essential requirements?

Reference: Regulation (EC) No 216/2008, Regulation (EU) No 965/2012 on Air Operations as amended by Regulation (EU) No 800/2013

Essential requirements are a legal means of setting high level objectives and obligations on authorities, persons and organisations in order to achieve the objectives of the Basic Regulation ((EC) No 216/2008). Implementing rules are then developed on the basis of these essential requirements, to further detail how to achieve these objectives and obligations. The Basic Regulation has annexes containing essential requirements for:

  • airworthiness (in Annex I),
  • certain aircraft that fall outside the scope of the Agency's activities (Annex II),
  • pilot licensing (Annex III),
  • air operations (Annex IV),
  • qualified entities in the case of certification (Annex V),
  • aerodromes (Annex Va) and
  • ATM/ANS and air traffic controllers (Annex Vb).

For example, the implementing rules for air operations (e.g. Regulation (EU) No 965/2012) are developed using the essential requirements as a starting point. For certain aspects and types of operation, the essential requirements do not need to be further elaborated on with a specific implementing rule. For example, in the case of non-commercial operations with other-than-complex motor-powered aircraft, some of the responsibilities of the pilot-in-command are set out in adequate detail in 1.b and 1.c of Annex IV to the Basic Regulation, and did not need to be further detailed in implementing rules. For legal certainty, the essential requirements should not be repeated in the implementing rule, but to support industry in identifying the requirements with which they should comply, the Agency makes a reference to the essential requirement from the implementing rule:
“NCO.GEN.105 Pilot-in-command responsibilities and authority

a) The pilot-in-command shall be responsible for:

(1) the safety of the aircraft and of all crew members, passengers and cargo on board during aircraft operations as referred to in 1.c of Annex IV to Regulation (EC) No 216/2008”.

View

Was this helpful?

Vote up  36
Vote down  15

What is the 'Cover Regulation'?

Reference: Regulation (EU) No 1178/2011, Regulation (EU) No 290/2012, Regulation (EU) No 965/2012, Regulation (EU) No 800/2013

The 'Cover Regulation' designates:

  • The first 12 articles of Commission Regulation (EU) No 1178/2011 of 3 November 2011 laying down technical requirements and administrative procedures related to civil aviation aircrew pursuant to Regulation 216/2008 of the European Parliament and of the Council (OJ L 311, 25.11.2011, p. 1) as amended by Commission Regulation (EU) No 290/2012 of 30 March 2012 (OJ L 100, 5.4.2012, p. 1) - the full regulation is available here;
  • The first 10 articles of Commission Regulation (EU) No 965/2012 of 5 October 2012 laying down technical requirements and administrative procedures related to air operations pursuant to Regulation 216/2008 of the European Parliament and of the Council (OJ L 296, 25.10.2012, p. 1) as amended by Commission Regulation (EU) No 800/2013 (OJ L 227, 24.08.2013, p.1).

The Cover Regulation:

  • explains the principles and considerations of the legislator when adopting the regulation (the 'whereas' clauses);
  • describes the regulation's objective and scope;
  • defines the terms used in the Cover Regulation;
  • indicates to whom/what the regulation and its annexes apply;
  • provides one or more dates from when the rules become applicable (opt-out provisions), including any grandfathering and transition measures for the adaptation to the new rules.

Regulation (EU) No 1178/2011 as amended by Regulation (EU) No 290/2012 has been termed by the Commission as the 'Aircrew Regulation'.

The Aircrew Regulation is thus composed of the Cover Regulation (12 Articles) and seven annexes, which contain the implementing rules on pilot licensing (Annex I - Part FCL), conversion of existing national licences (Annex II), conditions for the acceptance of licences issued by or on behalf of third countries (Annex III), medical certification and attestation (Annex IV - Part MED), qualification of cabin crew (Annex V - Part CC), authority requirements for aircrew (Annex VI - Part ARA) and organisation requirements for aircrew (Annex VII - Part ORA).

Regulation (EU) No 965/2012 has been termed the 'Air OPS Regulation'.

The Air OPS Regulation is thus composed of the Cover Regulation (10 Articles) and seven annexes, Annex I Definitions for terms used in Annexes II to VII, Annex II Authority requirements for air operations (Part ARO), Annex III Organisation requirements for air operations (Part ORO), Annex IV Commercial air transport operations (Part CAT), Annex V Specific approvals (Part SPA), Annex VI Non-commercial operations with complex motor-powered aircraft (Part NCC), Annex VII Non-commercial operations with other-than-complex motor-powered aircraft (Part NCO), which contain the implementing rules on air operations for commercial and non-commercial operations with aeroplanes, helicopters, sailplanes and balloons. Annex VIII Specialised Operations (Part SPO), to be published this year, will complete the Air Operations package. If you'd like to see the structure of the Air OPS regulation, click here.

View

Was this helpful?

Vote up  17
Vote down  3

What do 'grandfathering', 'transition measure' and 'opt-out' mean?

Reference: Regulation (EU) No 1178/2011, Regulation (EU) No 290/2012, Regulation (EU) No 965/2012, Regulation (EU) No 800/2013, Regulation (EU) No 71/2014, Regulation (EU) No 83/2014

Aircrew Regulation

In the Aircrew Regulation, 'grandfathering' designates the legal recognition and acceptance of certificates issued by national authorities prior to the entry into force of the Aircrew Regulation. In the Cover Regulation, 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.

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.

A 'transition measure' is a means of allowing a gradual change to the new rules and its scope and timeline are clearly stated within the Cover Regulation. Several examples can be found in the Aircrew Regulation, such as in Article 11c (in relation to the obligation of Member States regarding transfer of records and certification processes of those organisations for which the Agency is the competent authority) and Article 4 (1) obligation of Member States to adapt grandfathered pilot licences to the new licence format by a certain date of the Cover Regulation. 
The 'opt-out' can also be considered as a form of transition measure applicable to Member States. Opt-out provisions allow Member States to decide not to implement the new EU Regulation for a certain period of time, delaying the date of applicability of the new regulation within that Member State. This requires the Member State to notify the European Commission and the Agency of the 'opt-out', describing the reasons for such derogation and the programme for implementation. Article 12 (1) of the amended Cover Regulation allowed for a general opt out to Annexes I to IV until 8 April 2013. Other specific opt-outs are listed in Article 12 (2) to (6).

Air OPS Regulation

In the Air OPS Regulation, 'grandfathering' designates the legal recognition and acceptance of certificates issued by national authorities prior to the entry into force of the Air OPS Regulation. In the Cover Regulation, the conditions for the 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 EU-OPS to the new air ops rules. In the case of air operations, provisions on grandfathering consider EU-OPS AOCs issued in compliance with given regulations and by a certain date as being in compliance with the new Air OPS Regulation.

A 'transition measure' is a means of allowing a gradual change to the new rules and its scope and timeline are clearly stated within the Cover Regulation. An example to be found in the Air OPS Regulation is Article 7.1 obligation of Member States to issue AOC complying with the new format by a certain date.

The 'opt-out' can also be considered as a form of transition measure applicable to Member States. Opt-out provisions allow Member States to decide not to implement the new EU Regulation and its amendments for a certain period of time, delaying the date of applicability of the new regulation within that Member State. This requires the Member State to notify the European Commission and the Agency of the 'opt-out', describing the reasons for such derogation and the programme for implementation. Article 10.2 of the Cover Regulation ((EU) No 965/2012) allows for a general opt out to Annexes I to V until 28 October 2014. The amendments to Regulation (EU) No 965/2012 have different dates of applicability.

View

Was this helpful?

Vote up  10
Vote down  7

What do 'enter into force' and 'applicability' mean in the Cover Regulation?

Reference: Regulation (EU) No 1178/2011 on Aircrew and its amendments, Regulation (EU) No 965/2012 on Air Operations and its amendments

When Regulations are published in the Official Journal of the European Union they invariably include several dates. The date of entry into force is usually expressed as the 20th day following publication of the Regulation in the Official Journal of the European Union. It means that the EU rules have been adopted and published - thus producing legal effects -, but are not necessarily mandatory on the date of entry into force. The date when they become mandatory is the date of applicability.

The Aircrew Regulation applies from 8 April 2012.

The Regulation (EU) No 965/2012 on Air Operations applies from 28 October 2012. Its further amendments have different dates of entering into force and of applicability.

However, since Article 12 of the Aircrew Regulation and Article 10 of the Air OPS Regulation include several opt-out provisions, this means that entire Annexes and/or specific parts of the Annexes will not be applicable until the end of the out-out periods, in case Member States take up this possibility. This means that the entry into force and applicability dates are common to all Member States, but due to the possibility of opt-outs, concrete implementation of specific provisions of Annexes or entire Annexes may vary among Member States. Please find Derogations to Aircrew Regulation ((EU) No 1178/2011, (EU) No 290/2012) and Air Operations Regulation ((EU) No 965/2012 and (EU), No 800/2013) here.

View

Was this helpful?

Vote up  21
Vote down  6

When will the new rules on air operations be applicable?

Reference: Regulation (EU) No 965/2012 on Air Operations and its amendments

Regulation (EU) No 965/2012 entered into force on 28 October 2012.

Article 10 of the Air OPS Regulation includes an opt-out provision allowing Member States to postpone the applicability of Annexes I to V until 28 October 2014. This means that entire Annexes and/or specific parts of the Annexes will not be applicable if a Member States chooses to opt-out. The Agency has published an overview of the opt-out period applied by Member States here.

The amendments to the Regulation (EU) No 965/2012 have different applicability dates:

  • Commission Regulation (EU) No 800/2013 on non-commercial operation became applicable on 25 August 2013 and the opt-out period is 3 years.
  • Commission Regulation (EU) No 71/2014 on operational suitability data was published on 27 January 2014; it entered into force on the twentieth day following that of its publication and must be applied not later than 18 December 2017 or two years after the approval of the operational suitability data, whichever is the latest.
  • Commission Regulation (EU) No 83/2014 on flight and duty time limitations and rest requirements was published on 29 January 2014, entered into force on the twentieth day following that of its publication and shall apply from 18 February 2016 and from 17 Feb 2017 for ORO.FTL.205(e).

Once the Implementing Rules have been adopted, it is still possible that transition measures defer their applicability to a later date. Therefore, the exact date of applicability of each requirement will depend on the transition measures adopted by the European Commission. Until the date the new Implementing Rules apply, Member States' national rules and EU-OPS remain in force.

View

Was this helpful?

Vote up  13
Vote down  2

What is the comitology procedure?

Reference: Regulation (EU) No 182/2011

Under the Treaty on the Functioning of the European Union (TFEU), the European Commission is responsible for the required implementation of Union legislation in many areas. When exercising these delegated powers, the Commission is often obliged to work with national civil servants appointed by Member States in different committees. These committees, which are a forum for discussions and the voicing of opinions, are chaired by the European Commission.

For the implementation of Regulation (EC) No 216/2008 (the Basic Regulation), the European Commission is assisted by the EASA Committee and by the Single European Sky Committee. Another committee of importance as regards aviation safety is the Air Safety Committee, which is best known for being the guardian of the so-called 'Safety list' as provided by Directive 2004/36/CE of the European Parliament and of the Council of 21 April 2004 on the safety of third-country aircraft using Community airport as amended by Regulation (EC) No 2111/2005 of the European Parliament and of the Council of 14 December 2005 on the establishment of a Community list of air carriers subject to an operating ban within the Community and on informing air transport passengers of the identity of the operating air carrier, and repealing Article 9 of Directive 2004/36/EC.

The procedures which govern the work of these committees follow the standard procedures approved by Regulation (EU) No 182/2011 of the European Parliament and of the Council of 16 February 2011 laying down the rules and general principles concerning mechanisms for control by Member States of the Commission's exercise of implementing powers. It replaces former Decision 1999/468/EC. This Regulation introduces a new amended 'comitology' procedure. The latest Comitology Regulation and other relevant information on the new comitology procedure can be consulted here.

View

Was this helpful?

Vote up  3
Vote down  7

Can the information provided on EASA's FAQ be considered as legally binding?

EASA is not the competent authority to interpret EU Law. The responsibility to interpret EU Law rests with the judicial system, and ultimately with the European Court of Justice. EASA cannot even provide an 'authentic interpretation' (which is an official interpretation of a statute issued by the statute's legislator). Therefore any information included in these FAQs shall only be considered as EASA's understanding on a specific matter, and cannot be considered in any way as legally binding.

View

Was this helpful?

Vote up  18
Vote down  2

Why can't I find EU-OPS on the Agency website?

Reference: Regulation (EU) No 965/2012 on Air Operations, associated Decisions (AMC/GM)

EU-OPS is published in the Official Journal of the EU as Regulation (EC) No 1899/2006 of the European Parliament and of the Council of 12 December 2006 amending Council Regulation (EEC) No 3922/91 on the harmonisation of technical requirements and administrative procedures in the field of civil aviation (OJ L 377, 27.12.2006, p. 1). It is available online via EUR-Lex. Although the Agency assists the Commission in administering this Regulation, any enquiries related to EU-OPS, if not handled by your national aviation authority, should be addressed to the Commission.

The JAA published TGL 44 in 2008, containing extensive guidance material for use with EU-OPS. This is available online.

EU-OPS continues to apply until the new requirements of Regulation (EU) No 965/2012 on Air Operations and its amendments are applicable in your Member State.

View

Was this helpful?

Vote up  20
Vote down  65

What is the status of 'Implementing Rules', 'Acceptable Means of Compliance', Alternative Means of Compliance (AltMOC), 'Guidance Material' and 'Frequently Asked Questions'?

Implementing rules (IRs): EU law in the area of civil aviation generally defines safety objectives at the level of essential requirements and implementing rules, whereas detailed implementation aspects are included as Certification Specifications (CS) or Acceptable Means of Compliance (AMC). EU law is directly applicable (full part of Member States' legal order). These IRs are binding in all their aspects.

AMC and Guidance Material (GM): The AMC and GM are Agency measures. AMCs are defined as non-binding standards adopted by the Agency to illustrate means to establish compliance with the Basic Regulation and its Implementing Rules.

The AMCs issued by the Agency are not of a legislative nature; therefore they cannot create obligations on the regulated persons, who may decide to show compliance with the applicable requirements using other means. 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.

GM is issued by the Agency to assist in the understanding of the Basic Regulation, its IRs and CSs.

For a clear differentiation between the AMC and AltMOC, please consult the relevant FAQ page.

Frequently Asked Questions: FAQs are published on the Agency (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 Agency FAQs are necessary to share information and enable to get a common understanding.

These FAQs are not additional GM.

View

Was this helpful?

Vote up  20
Vote down  2

Do the new EASA rules also apply to non-commercial operations?

Reference: Regulation (EU) No 965/2012 on Air Operations as amended by Regulation (EU) No 800/2013, (EU) 71/2014 and (EU) 83/2014

Yes, the new rules also apply to non-commercial operations. For general aviation and business/corporate aviation, the applicable rules are partly determined by the type of aircraft being flown: Annex VI (Part NCC: non-commercial operations with complex motor-powered aircraft) or Annex VII (Part NCO: non-commercial operations with other-than-complex motor-powered aircraft) will apply. The definition of complex motor-powered aircraft is found in Article 3 of the Basic Regulation and 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 also contained in Article 3 of the Basic Regulation:

“(i) 'commercial operation' shall mean 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 aircraft being flown.

In addition, Part SPA applies to any operations 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 respectively the authority and organisation requirements regarding air operations. Annex III applies to operators of complex motor-powered aircraft, both commercial and non-commercial.

View

Was this helpful?

Vote up  29
Vote down  5

I am not familiar with the new rule structure. Which parts apply to me?

Reference: Regulation (EU) No 965/2012 on Air Operations and the associated Decisions

This is determined by the nature of your flight, and for non-commercial operation by the type of aircraft flown. The following diagram indicates under which requirements your flight should be operating.

Commercial operations Commercial air transport (CAT) Technical rules: Part CAT
Specific approvals: Part SPA
Operator requirements: Part ORO
Non-CAT 
(specialised operations - e.g. aerial work
Technical rules: Part SPO
Specific approvals: Part SPA
Operator requirements: Part ORO
Non-commercial operations Non-commercial operations 
(including training flights)
With complex motor-powered aircraft: Technical rules: Part NCC
Specific approvals: Part SPA
Operator requirements: Part ORO
With other-than-complex motor-powered aircraft Technical rules: Part NCO
Specific approvals: Part SPA
Specialised operations 
(e.g. aerial work)
Technical rules: Part SPO
Specific approvals: Part SPA
With complex motor-powered aircraft: also Part ORO
View

Was this helpful?

Vote up  30
Vote down  10

How can I find out where a rule from EU-OPS / JAR-OPS 3 has been transposed in the new Regulation (EU) 965/2012 on Air Operations and its amendments, as well as its associated Agency Decisions, and if any changes have been introduced?

Reference: Regulation (EU) No 965/2012 on Air Operations, associated Decisions (AMC/GM)

The Agency has published a cross-reference table to assist industry in transitioning to the new rules. This table contains detailed information on the transposition of EU-OPS / JAR-OPS 3 provisions (both Section 1 and Section 2 - for aeroplanes, TGL 44) into the new Implementing Rules (IR), Acceptable Means of Compliance (AMC) and Guidance Material (GM):

  • new rule reference and rule title;
  • old rule reference and rule title;
  • indication of any differences to EU-OPS / JAR-OPS 3 provisions by stating “No change”, “Amended”, “New” or “Not transposed”; and
  • short description of the differences, if any, between the old and new rules.

With this cross-reference table one can analyse in detail where and how the old provisions have been transposed into the new regulatory framework.

View

Was this helpful?

Vote up  18
Vote down  8

Which operational requirements (EU/EASA Parts) apply to flight activities carried out by Manufacturer (i.e. ferry flights, demonstration flights, etc.)?

Reference: Regulation (EU) No 965/2012 on Air Operations

At the present stage no EU requirements exist for flights related to design and production activities (“manufacturer flights”). Instead these flights are regulated under national law. This is laid down in Paragraph 3 of Article 6 of Regulation (EU) No 965/2012 as follows:

“By way of derogation from Article 5(1) [air operations are regulated on a EU level], flights related to the introduction or modification of aircraft types conducted by design or production organisations within the scope of their privileges shall continue to be operated under the conditions set out in Member States' national law.”

However, the Agency started a rulemaking task (RMT.0348/0349) on “Flights related to design and production activities”. The goal is to establish a European regulatory framework for manufacturer flights including ferry flights, demo flights etc. At the present stage, a rulemaking group is working on a draft proposal to be published as “Notice of Proposed Amendments (NPA)” in 2014.

View

Was this helpful?

Vote up  8
Vote down  11

Definitions

What are critical phases of flight?

Reference: Regulation (EU) No 965/2012 on Air Operations, Annex I Definitions

Annex I (Definitions) of the Regulation (EU) 965/2012 on Air Operations contains definitions for critical phases of flight for aeroplane and helicopters:

“'Critical phases of flight' in the case of aeroplanes means the take-off run, the take-off flight path, the final approach, the missed approach, the landing, including the landing roll, and any other phases of flight as determined by the pilot-in-command or commander.

'Critical phases of flight' in the case of helicopters means taxiing, hovering, take-off, final approach, missed approach, the landing and any other phases of flight as determined by the pilot-in-command or commander.”

As one can see from these definitions, for helicopters taxiing is defined as a critical phase of flight, while for aeroplanes it is not. Rules for activities considered acceptable during critical phases of flight are provided in the Regulation (EU) No 965/2012 on Air Operations - in Annex III (Part ORO), Annex IV (Part CAT), Annex VI (Part NCC), Annex VII (Part NCO) and Annex VIII (Part SPO). Basically, these Implementing Rules require crew members during critical phases of flight:

  • to be seated at his/her assigned station; and
  • not to perform any activities other than those required for the safe operation of the aircraft.
View

Was this helpful?

Vote up  39
Vote down  8

What are 'Sterile Flight Deck Procedures'?

Reference: Regulation (EU) No 965/2012 on Air Operations, Annex I (Definitions) and Annex III (Part ORO)

The term 'Sterile Flight Deck' is used to describe any period of time when the flight crew members shall not be disturbed e.g. by cabin crew, except for matters critical to the safe operation of the aircraft and/or the safety of the occupants. In addition, during these periods of time the flight crew members should focus on their essential operational activities without being disturbed by non-flight related matters, i.e. flight crew members should avoid non-essential conversations, should not make non-safety related announcements towards the passengers, etc.

Sterile flight deck procedures are meant to increase the flight crew members' attention to their essential operational activities when their focused alert is needed, i.e. during critical phases of flight (take-off and landing, etc.), during taxiing and below 10 000 feet (except for cruise flight).

The Agency issued draft rules addressing sterile flight deck procedures in June 2013 (Opinion 05/2013) to the European Commission. Once adopted, these rules will be incorporated in the Regulation on Air Operations. The Agency expects that the sterile flight deck procedures will be in place in 2014.

View

Was this helpful?

Vote up  22
Vote down  5

What is the difference between 'commercial operation' and 'commercial air transport (CAT) operation'?

Reference: Regulation (EC) No 216/2008 ('the Basic Regulation'), Regulation (EU) No 965/2012 on Air Operations

The term 'commercial operation' is defined in Article 3 of the Basic Regulation as follows:

'Commercial operation' shall mean 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 a customer, where the latter has no control over the operator.

The term 'commercial air transport (CAT) operation' is defined in Article 2 of Regulation (EU) No 965/2012 as follows:

'Commercial air transport (CAT) operation' means an aircraft operation to transport passengers, cargo or mail for remuneration or other valuable consideration.

The two definitions make it clear that 'commercial operations' include 'CAT operations'.

View

Was this helpful?

Vote up  101
Vote down  41

Part-ARO

AMC2 ARO.GEN.305(c) Oversight programme (c) stipulates that audits should include at least one on-site audit within each oversight planning cycle. What is meant by an 'on-site audit' in this sentence? Could it be so that every audit undertaken by an NAA could be performed while sitting in the NAA's office and reviewing operator's documents and procedures and only one of those audits should be undertaken in a way that NAA inspectors actually visit an operator on-site?

Reference: Regulation (EU) No 965/2012 on Air Operations, Annex II (Part ARO, ARO.GEN and ARO.RAMP)

There is no further guidance on how many on-site audits should actually be performed. This decision depends on the confidence of the authority in the operator, on results of past certification and/or oversight activities required by ARO.GEN and ARO.RAMP and on the assessment of associated risks. The number of on-site audits is therefore part of the oversight responsibility of the authority.

View

Was this helpful?

Vote up  11
Vote down  0

How do the provisions on wet-leasing articulate with the future Regulation applying to Third Country Operators (TCO)?

Reference: Regulation (EU) No 965/2012 on Air Operations, Annex III (Part ORO)

The TCO authorisation issued by the Agency is no substitute for requirements regarding wet-lease agreements between EU and third country operators that are contained in Part ORO of Regulation (EU) No 965/2012 on Air Operations. For wet-lease agreements, the TCO operator must demonstrate equivalence to EU safety requirements. Before entering into a wet-lease agreement, the EU operator should demonstrate to the authority that (1) the TCO has a valid AOC, (2) that safety standards of the TCO regarding continuing airworthiness and air operations are equivalent to the EU continuing airworthiness requirements 2042/2003 (593/2012) and (3) the aircraft has a standard Certificate of Airworthiness (CofA) issued in accordance with ICAO Annex 8.

View

Was this helpful?

Vote up  9
Vote down  3

Must the competent authority check and approve the content of the operator's Safety Management Manual?

Reference: Regulation (EU) No 965/2012 on Air Operations, Annex II (Part ARO), Annex III (Part ORO)

As stated in ORO.AOC.100, an operator has to submit, as part of its application for an AOC, a description of its management system, including the organisational structure, which constitutes its safety management manual, whose content is described in AMC1 and AMC2 to ORO.GEN.200(a)(5).
The Competent Authority has to check the content of the operator's Safety Management Manual (SMM) as mentioned in ARO.GEN.310(a) and in the corresponding AMC to ARO.GEN.310.

ARO.GEN.310 INITIAL CERTIFICATION PROCEDURE - ORGANISATIONS

(a) Upon receiving an application for the initial issue of a certificate for an organisation, the competent authority shall verify the organisation's compliance with the applicable requirements. This verification may take into account the statement referred to in ORO.AOC.100 (b).
[...]

AMC1 ARO.GEN.310(a) INITIAL CERTIFICATION PROCEDURE - ORGANISATIONS
VERIFICATION OF COMPLIANCE

(a) Upon receipt of an application for an air operator certificate (AOC), the competent authority should:

(1) assess the management system and processes, including the operator's organisation and operational control system;
(2) review the operations manual and any other documentation provided by the organisation; [...]

Information on the content of the operator's Safety Management Manual (SMM), which can be part of the Operations Manual or included in a separate manual, can be found in AMC1 and AMC2 to ORO.GEN.200(a)(5). It should be noted that the SMM is not required to be approved according to ORO.GEN.200(a)(5) and the related AMCs. Nevertheless, changes affecting the operator's management system are required to be approved (ORO.GEN.130 + GM1) and these changes would have to be reflected in the operator's manual dealing with Safety management:

AMC1 ORO.GEN.200(a)(5) MANAGEMENT SYSTEM DOCUMENTATION - GENERAL
[...]

(b) The operator's management system documentation may be included in a separate manual or in (one of) the manual(s) as required by the applicable Subpart(s). A cross reference should be included.

ORO.GEN.130 CHANGES

(a) Any change affecting:

(1) the scope of the certificate or the operations specifications of an operator; or
(2) any of the elements of the operator's management system as required in ORO.GEN.200 (a)(1) and (a)(2),
shall require prior approval by the competent authority.

View

Was this helpful?

Vote up  8
Vote down  2

How do the provisions on code-sharing articulate with the future Regulation applying to Third Country Operators (Part TCO)?

Reference: Regulation (EU) No 965/2012 on Air Operations, Annex III (Part ORO)

Regarding code-sharing, Regulation (EU) No 965/2012 on Air operations requires from the EU Operator, who wishes to enter into a code-sharing agreement with a third country operator (TCO), compliance with the requirements of Annex III to Regulation (EU) No 965/2012. This means the TCO as a code-share partner will undergo comprehensive audits for the initial verification of compliance and continuous compliance with the applicable ICAO standards [AMC1 ORO.AOC.115(a)(1)]. These audits can be performed either by the EU operator itself or a third party provider. The AMC (AMC2 ORO.AOC.115(b)) refers to the possibility of using industry standards. The audit will focus on the operational, management and control systems of the TCO (see AMC1 ORO.AOC.115(a)(1)). Continuous compliance of the code sharing TCO with the applicable ICAO standards will be performed on the basis of a code-share audit programme (see AMC1 ORO.AOC.115(b)).

This means that the audit and verification requirements contained in Part ORO of Regulation 965/2012 cannot be substituted by a TCO authorisation issued by the Agency. For code-share, an EU operator must, in addition to the TCO authorisation, audit and monitor the TCO.

View

Was this helpful?

Vote up  4
Vote down  1

Part-ORO

ORO.GEN

ORO.GEN.110 (a): “The operator is responsible for the operation of the aircraft in accordance with Annex IV to Regulation (EC) No 216/2008”. Is this requirement met when an Operator follows the Implementing Rules (965/2012)?

Reference: Regulation (EU) No 965/2012 on Air Operations, Annex III (Part-ORO)

The Essential Requirements (ER) are as applicable as the implementing rules.

The operators are responsible for checking that they comply with all the Essential Requirements contained in Annex IV of the Basic Regulation (EC 216/2008).

Some implementing rules make a direct reference to the Essential Requirements. This is the case when an ER is not further developed in the implementing rules.

View

Was this helpful?

Vote up  21
Vote down  22

What are the responsibilities of the AOC holder required to implement a management system in accordance with ORO.GEN.200 in regards to continuing airworthiness management and contracted maintenance?

Reference: Regulation (EU) No 965/2012 on Air Operations, Annex III (Part-ORO); Regulation (EC) No 2042/2003 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.

If the operator’s continuing airworthiness activities do not comply with the new management system requirements adopted with Part-ORO the competent authority may not raise any finding in reference to Part-M Subpart G, but may do so under Part-ORO should it consider that the operator’s safety risk management process does not sufficiently capture those risks stemming from the continuing airworthiness management activities that may impact the safety of operations. The integration of safety management across all activities will lead to increased efficiency and effectiveness in hazard identification and risk management as compared to a system where activities are being dealt with in isolation through separate management systems. This will improve the assessment of risks identified and ensure better allocation of resources to address these risks, by eliminating conflicting or duplicating procedures and objectives.

When it comes to assessing compliance with Part-ORO competent authorities should acknowledge that implementing effective safety risk management capabilities for all activities subject to the approval will take time and therefore a balanced approach for checking compliance is needed to enable a smooth transition towards the new management system requirements.

Considering the benefits of taking a holistic, integrated approach to management system for effective safety management, competent authorities should also not mandate the implementation of separate management systems for the different approvals of the same organisation. Competent authorities should instead focus on assessing whether the management system implemented is adequate as regards the size, nature and complexity of the activities it is deemed to cover.

2. Maintenance

The issue is slightly different in the area of contracted maintenance: As the Part-145 requirements have not yet been amended to align with the management system framework adopted for air operations, the maintenance organisation may not have established a management system to effectively identify maintenance specific hazards and manage related risks. However, the operator would still need to consider such hazards and risks entailed by contracted maintenance, as it would do for any other contracted activity that has an impact on aviation safety, under its own management system. Once Part-145 organisations will have implemented the new management system requirements including safety risk management, the operator will be able to establish an interface with the hazard identification and risk management processes of the maintenance organisation and consider the contracted organisation’s capability to properly address maintenance specific hazards and risks for their own safety risk management.


This FAQ addresses the case of  EU licenced air carriers, meaning operators holding both and AOC in accordance with Regulation (EU) No. 965/2013 and an operating licence in accordance with Regulation (EC) No 1008/2008

View

Was this helpful?

Vote up  17
Vote down  16

Is there a difference between safety risk management (SRM) and SMS?

Reference: Regulation (EU) No 965/2012 on Air Operations, ICAO Annex 19

ICAO defines SMS as “a systematic approach to managing safety, including the necessary organisational structures, accountabilities, policies and procedures.”

While SRM is an essential element within a management system for safety, it is not the only element required. To be effective, SRM needs a structured approach and an organisational framework with clearly defined policies, safety responsibilities and accountabilities. Such framework is essential to facilitate and encourage hazard identification, ensure a structured & consistent approach to risk assessment, as well as for allowing informed decisions to be made at the right organisational level, e.g. in relation to risk acceptability or different risk mitigation options. For example, the organisation needs to put in place policies, procedures and mechanisms for internal safety reporting and then maintain the conditions for allowing such reporting to take place.

Also, in order to ensure that the organisation is continually managing its risks it needs to monitor how well it performs, both in terms of effectiveness of risk controls implemented and effective compliance with applicable requirements. This is part of safety assurance, which is another component of an SMS as per ICAO Annex 19.

Additionally the organisation has to train their staff to fulfil their duties, including those related to any safety management task and to properly communicate on any safety relevant issue.

All this should lead to ensuring a systematic approach to SRM and help fostering the necessary ‘culture’ within the organisation to enable careful management and sound understanding of risk, including in day-to-day activities.

In conclusion, SRM, while being a core element of any management system for safety, should not be singled out as the only element required to implement such system.

See also the FAQ on SMS versus management system above.

View

Was this helpful?

Vote up  28
Vote down  8

Why do the EASA Air Operations rules use the term ‘management system’ (ORO.GEN.200) and not ‘safety management system’ (SMS), like in ICAO Annex 19? Is there a difference between the two concepts?

Reference: Regulation (EU) No 965/2012 on Air Operations, Annex III (Part ORO)

In the area of SMS the Agency promotes consolidated general requirements for an organisation’s management system. The starting point for drafting the ‘first extension’ rules are the essential requirements attached in the annexes to the EASA Basic Regulation (Regulation (EC) No 216/2008) and these refer to ‘management system’, cf.  the essential requirements for Operations (Annex IV):

“the operator must implement and maintain a management system to ensure compliance with these essential requirements for operations and aim for continuous improvement of this system; and” ….

The underlying concept is that for managing safety it is essential to take a holistic approach and to implement the new safety risk management (SRM) related processes while making use of and integrating these into the already existing management system (e.g. quality system as per JAR-OPS/ EU-OPS). For example, the internal audit process (compliance monitoring) is kept as an essential element of the management system, while ICAO Annex 19 is not that clear about it.

Hence, organisations should be encouraged to integrate the new SRM elements into their existing system and articulate these with the way the organisation is managed, addressing every facet of management, as any organisational change and any decision (even in areas such as Finance, Human Resources) will need to be assessed for their impact on safety. Such integrated approach to management is much more efficient for monitoring compliance, managing risks and maximising opportunities.

Finally, it is not required that organisations adapt their terminology to that used in Part-ORO: Should they wish to refer to SMS, QMS or SQMS etc., this is possible as long as they can demonstrate that all requirements are met. In the same vein, they can still use the title ‘quality manager’, although the rules refer to compliance monitoring manager.

View

Was this helpful?

Vote up  30
Vote down  14

If an operator is considered complex , may a person hold the position as a Safety Manager and at the same time be one (or more) of the nominated persons as described in ORO.GEN.210(b), taken into account the size and complexity of the operator?

There is no guidance indicating that the safety manager may not be a nominated person in the organisational set up of a complex operator.

However, when assessing the organisational set-up of a complex operator, please consider also GM1 ORO.GEN.200(a)(1) point (b): “Regardless of the organisational set-up it is important that the safety manager remains the unique focal point as regards the development, administration and maintenance of the operator’s safety management system”.

In summary, the role of the safety manager is not addressed at the level of implementing rules. The acceptable means of compliance describe the functions of the safety manager in complex operators. The guidance material emphasises on the importance of having a unique focal point for the operator’s safety management system.

It is for the operator to determine if the combination of the safety manager function with that of a nominated person allows to fulfil the management functions of the nominated persons post associated with the scale and scope of the operation. It is then for the competent authority  to assess if such organisational set-up corresponds to the size of the operator and the nature and complexity of its activities, taking into account the hazards and associated risks inherent in these activities.

For the assessment of the appropriateness of the organisational set-up, the competent authority should also be satisfied that the operator complies with ORO.GEN.210(c) “The operator shall have sufficient qualified personnel for the planned tasks and activities to be performed in accordance with the applicable requirements.”

View

Was this helpful?

Vote up  16
Vote down  2

I am looking for the acceptance of post holders, particularly the Safety manager. In the AMC we agreed on the functions of the Safety manager, but did we agree on his or her acceptance?

Reference: Regulation (EU) No 965/2012 on Air Operations, Annex II (Part ARO, ARO.GEN.310, ARO.GEN.330), Annex III (Part ORO, ORO.GEN.130)

Part ORO does not mention anymore the notion of acceptance/acceptability of nominated persons. This is now replaced by the notion of changes requiring prior approval or changes not requiring prior approval.

During the initial certification process, nominations of personnel in general are considered to be part of the verification of compliance performed by the competent authority and therefore covered by the issuance of the AOC.

Regarding changes to certified organisation, the notion of changes requiring prior approval/changes not requiring prior approval applies and therefore, a formal approval of certain change is required. Guidance is provided through GM1 ORO.GEN.130(a) and GM3 ORO.GEN.130(c). Likewise, upon initial certification, the competent authority may agree with the organisation on a more specific scope of changes that do not require prior approval, on the basis of ARO.GEN.310(c), and within the limits of the applicable requirements. Items not required to get a prior approval are managed by the organisation based on a procedure approved by the competent authority for the management of such changes. In any case, these changes have to be notified to the competent authority which will verify compliance with the applicable requirements (cf. ORO.GEN.130(c) and ARO.GEN.330(c)).

Regarding the specific case of the safety manager, it should be noted that there is no requirement for a safety manager at an implementing rule level. The nomination of a safety manager is one means to comply with the IR objective. Therefore, a change in safety manager is not listed in the GMs to ORO.GEN.130: A change in safety manager is not considered a change requiring a prior approval from the competent authority, unless, the accountable manager fulfils the role of safety manager, in which case a change would obviously require prior approval.

The above references are those to Regulation (EU) No 965/2012; the same provisions are included in Regulation (EU) No 290/2012 (ARA/ORA).

View

Was this helpful?

Vote up  35
Vote down  5

Regarding ORO.GEN.200, could a commercial operator of complex motor powered aircraft, such as the Cessna Citation Bravo that operates within Europe and with no SPAs, be considered non-complex?

Reference: Regulation (EU) No 965/2012 on Air Operations, Annex III (Part ORO)

As defined in AMC1 ORO.GEN.200(b) the criterion in terms of full-time equivalents (FTEs) is the first one to be checked. This relates not only to the required organisational capability to implement and maintain a management system in line with Part ORO, but also to the fact that the larger the organisation gets, the more complex its procedures, communication and feedback channels will be, hence the need for robust processes related to hazard identification, safety risk management, performance measurement etc. For an organisation up to 20 FTEs, it is important to assess the 'risk profile' of the organisation in relation to the way it operates and this may justify the need for robust management processes for safety. The AMC defines the most relevant ones. The extent of contracting, the number, complexity and diversity of aircraft operated and type of operations (CAT, commercial, local, standard routes, hostile environment etc.) are all to be considered. It is important to note that the complexity criteria are included in an AMC to Part ORO and this makes a strong point as to the responsibility of the operator to make the assessment and justify the option chosen (complex or non-complex management system) to the satisfaction of the competent authority. If the option is to implement the provisions applicable to complex organisations, having details of management system implementation included in the form of AMCs to ORO.GEN.200, the operator may apply for an alternative means of compliance should it consider any of the elements of these AMCs inadequate for its specific type of organisation and operations.

View

Was this helpful?

Vote up  8
Vote down  6

ORO.MLR

How should an operator use external material in relation with its operations manual (OM)?

Reference: Regulation (EU) No 965/2012 on Air Operations, Annex III (Part ORO)

AMC1 ORO.MLR.100 states that when the operator chooses to use material from other sources, either this material is copied or the OM should contain a reference to the appropriate section of this material.

In any case, this material from another source is considered to be part of the OM and therefore should meet all the general requirements applicable to the OM. It includes:

  • (c) of ORO.MLR.100, which states that the OM shall be kept up-to-date;
  • (d) of ORO.MLR.100, which states that the personnel shall have easy access to the portions of the OM relevant for their duties;
  • (c)(3) of AMC1 ORO.MLR.100, which states that the content and amendment status of the manual is controlled and clearly indicated;
  • (d)(3) of AMC1 ORO.MLR.100, which states that the OM should include a description of the amendment process which specifies the method by which the personnel are advised of the changes.

Regulation (EU) No 965/2012 does not define any specific way to achieve this; therefore it is left to the operator to identify the best way to achieve these objectives. It is then the responsibility of the operator’s competent authority during the initial certification process/evaluation of change process to determine if the solution chosen by the operator allows meeting these requirements.

View

Was this helpful?

Vote up  22
Vote down  11

ORO.FTL

Status of the EASA FAQ: What is the legal status of the EASA FAQ? My own understanding of this document is that it has no legal standing at all, insofar as it is neither an Implementing Rule (IR), Acceptable Means of Compliance (AMC), Alternative Means of Compliance (AltMoc) nor even Guidance Material (GM).

EASA is not the competent authority to interpret EU Law. The responsibility to interpret EU Law rests with the judicial system, and ultimately with the European Court of Justice. Therefore any information included in these FAQs shall be considered as EASA's understanding on a specific matter, and cannot be considered in any way as legally binding.

The answers provided represent EASA’s technical opinion and also indicate the manner how EASA is evaluating, as part of its standardisation continuous monitoring activities, the application by national competent authorities of the respective regulatory provisions.

In the margins of its future rulemaking activities, EASA will consider the opportunity to include some of these FAQ in Subpart FTL as GM.

View

Was this helpful?

Vote up  1
Vote down  1

Applicability of FTL requirements of Regulation (EU) No 965/2012: Why should we comply with the FTL requirements of Regulation (EU) No 965/2012, since we have a policy in our company that says otherwise?

Regulation (EU) No 965/2012, including Subpart FTL, is mandatory in all Member States (MS).

This means that an operator cannot maintain a ‘policy’ it has had before the date of application of Subpart FTL of Regulation (EU) No 965/2012, unless the policy has been found compliant with that Regulation.

The competent authority of the operator is responsible for checking for compliance and for taking enforcement measure when a non-compliance is found.

View

Was this helpful?

Vote up  0
Vote down  0

Applicability of Regulation (EU) No 965/2012: What is the meaning of "applicable national flight time limitation legislation" in Article 8 (4) of Regulation 965/2012?

Reference: Regulation (EU) No 965/2012 as amended by Regulation (EU) No 83/2014
Topic: Applicability of Regulation (EU) No 965/2012

Article 8(4) of Regulation (EU) No 965/2012 stipulates that specialised operators continue to comply with applicable national flight time limitation legislation until EU implementing rules are adopted and apply.

 ‘Applicable national flight time limitation legislation’ is understood to mean the national law of the Member State in which the operator has its principal place of business, or, where the operator has no principal place of business, the place where the operator is established or resides.

View

Was this helpful?

Vote up  1
Vote down  2

Collective Labour Agreements (CLA) - Regulation (EU) No 83/2014: Our company has a Collective Labour Agreement (CLA) and an approved IFTSS. Both contain rules about FPD’s, DP’s and rostering. Which one is leading?

Recital (4) of Regulation (EU) No 83/2014 stipulates that: ‘The provisions of this Regulation do not preclude and should be without prejudice to more protective national social legislation and CLA concerning working conditions and health and safety at work.’

This means that more protective measures concerning FDP, DP and rostering, agreed under a CLA, are ‘leading’.

View

Was this helpful?

Vote up  2
Vote down  0

Applicability of Subpart FTL (see also ORO.AOC.125): Does Subpart FTL apply in relation to non-revenue flights (ferry flights)?

Any flight conducted by an AOC holder falls under Subpart FTL with the exception of:

  • some non-revenue flights such as: non-commercial, test, training, delivery, ferry and demonstration flights;
  • air taxi, single pilot and emergency medical services operations by aeroplane; and
  • CAT operations by helicopter, including HEMS.

However, aircraft positioning conducted by an AOC holder, immediately before or after a CAT sector counts as FDP and sector.

View

Was this helpful?

Vote up  2
Vote down  0

Acclimatisation ORO.FTL.105(1): How should we determine the state of crew member acclimatisation in complex rotations?

Acclimatised crew members

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).

Where the rotation  continues with duties to/from subsequent destinations, the greatest time difference from the reference time should be used for the purpose of rest in accordance with CS FTL.1.235(b)(3)(i). 

Time elapsed since reporting (h) in the tables ORO.FTL.105 (1) and CS FTL.1.235 (b)(3)(i) is the time that runs from first reporting at home base to the reporting at destination and includes the FDP from home base to destination plus layover time.   

View

Was this helpful?

Vote up  0
Vote down  3

Accommodation ORO.FTL.105 (3): Can the airport crew lounge be considered as “accommodation” for the purpose of standby or split duty? Can a hotel room for several crew members of the same gender be considered as “accommodation” for the purpose of standby and split duty?

As long as an airport crew lounge or a shared hotel room fulfils all criteria of ORO.FTL.105 (3) it could be used as accommodation.

View

Was this helpful?

Vote up  0
Vote down  3

Disruptive schedule ORO.FTL.105(8): Which criteria should be applied to determine a duty as disruptive if there is a time zone difference between the reporting point and the place where the duty finishes?

The criteria to be applied is the reference time e.g. the local time (LT) where the crew member reported for duty.

Example with “Late type” of Disruptive schedule:

LT in A = LT in B + 1 hour.

Day 1: The crew member starts the FDP acclimatised to A. He/she reports at 15:00 (LT-A) and finishes FDP in B at 23:30 (LT-B). It is a ‘Late finish’ because he/she is acclimatised to A, and FDP finishes at 00:30 (LT-A).
Rest in B. After resting in B, which is within two hours’ time difference from A, the crew member gets acclimatised to B.

Day 2: The crew member reports in B at 15:00 (LT-B) and finishes FDP in A at 00:30 (LT-A). It is not a late finish, because he/she is acclimatised to B, and the FDP finishes at 23:30 (LT-B).

View

Was this helpful?

Vote up  0
Vote down  0

Definition of duty and duty period, ORO.FTL.105 (10), ORO FTL 105 (11): Must the time for self-preparation (e.g. preparing for the checks associated with initial or recurrent training) be entered in the schedule of the crew members and recorded?

The time needed for self-preparation, is not a duty and is not recorded.  

View

Was this helpful?

Vote up  0
Vote down  0

Single day free of duty ORO FTL 105 (23): A ‘single day free of duty’ consists of one day and two local nights. Does the last day of several consecutive days free of duty need to contain at least one day and two nights?

Regulation (EU) No 965/2012 and Directive No 2000/79/EC do not contain a definition of multiple consecutive days free of duty. 

Regulation (EU) No 965/2012 defines ‘single day free of duty’ as ‘a time free of all duties and standby consisting of one day and two local nights, which is notified in advance. A rest period may be included as part of the single day free of duty;’
 
If the last day of a series of days off does not contain two local nights, then that last day does not meet the criteria of a single day free of duty. 

For example, if an operator assigns 3 consecutive local days free of duty ending at midnight, then only the first two consecutive ‘single’ days free of duty meet the definition.

When days off are used to mitigate cumulative fatigue, planning the last day of a group of days off to end at midnight, reduces the restorative effect of that last day off to a minimum.

View

Was this helpful?

Vote up  3
Vote down  3

Sector ORO.FTL.105 (24), (see also ORO.FTL.205 (f)(6)): In an abnormal or emergency situation a take-off might not be executed meaning that a sector was not completed. Such situation is likely to increase flight crew workload and fatigue. How could this be mitigated?

In such cases, in order to mitigate the increased workload and fatigue, the commander has the possibility to exercise commander’s discretion and decide on reducing the maximum daily FDP or increasing the minimum rest period.

ORO.FTL.205 (f)(6) requires operators to implement a non-punitive process for the use of commander’s discretion.

Also, if as a result of such situation a flight crew member feels unfit dues to fatigue, he/she may discontinue his duties on the aircraft for the day.

Regulation (EU) No 376/2014 on the reporting, analysis and follow-up of occurrences in civil aviation, requires the ability for crew members to report fatigue.  

View

Was this helpful?

Vote up  1
Vote down  0

Changes to a published roster: Is it possible to make changes to a published roster?

Yes, provided that the changes do not breach the limitations of the operator’s Individual Flight Time Specification Scheme (IFTSS).

All changes must be notified to the crew member before the pre-flight rest period commences so that the crew member is able to plan adequate rest as required by ORO.FTL.110 (a).

In support of this requirement the minimum period of time for notification of changes should be established by the operator and available in the Operations manual

View

Was this helpful?

Vote up  0
Vote down  0

Change of FDP after reporting: Can an FDP be changed after crew members have reported?

Yes, as long as the changes are within the maximum daily FDP limit which commenced at the time the crew members reported for the original duty, taking into account the actual number of sectors and crew configuration. 

View

Was this helpful?

Vote up  0
Vote down  0

Roster publication, (see also AMC1 ORO.FTL.110(a) and ORO.GEN.120): Are airline operators allowed to publish monthly rosters in less than 14 days in advance?

According to AMC1 ORO.FTL.110 (a), rosters should be published 14 days in advance. 

This requirement is an acceptable means of compliance (AMC). The AMC is one example of how operators could demonstrate compliance with this rule. 
In accordance with ORO.GEN.120, an operator may use an alternative means of compliance.

It is therefore possible to use an alternative means of compliance (AltMoc) for the publication of rosters, provided the operator has demonstrated that the requirements of ORO.FTL.110 (a) are met. 

An alternative means of compliance requires prior approval from the competent authority. 

The competent authority must notify all approved alternative means of compliance to EASA.

View

Was this helpful?

Vote up  3
Vote down  1

Reporting times ORO.FTL.110(c), (see also ORO.FTL.205(c)): Can the pre-flight reporting time for non-augmented flight crew members reporting for the same FDP be different?

No. The pre-flight reporting time for all non-augmented flight crew members reporting for the same FDP is the same.

The minimum reporting times, which have been defined by the operator in the Operations manual for different types of aircraft, operations and airport conditions, shall always apply to all flight crew.

Reporting time for the same FDP may be different between flight crew and cabin crew in accordance with ORO.FTL.205(c).

View

Was this helpful?

Vote up  0
Vote down  1

Operational robustness ORO.FTL.110(j): How should operational robustness be assessed?

The operator is required to have measures in place to protect the integrity of schedules and of individual duty patterns. 

The operator must monitor for exceedances to the planned flight duty periods and if the planned flight duty periods in a schedule are being exceeded more than 33% during a scheduled seasonal period, change a schedule and/or crew arrangements.

Operational robustness should be measured through performance indicators to determine if the planning is realistic and the rosters are stable.

The operator may measure the cases where a rostered crew pairing for a duty period is achieved within the planned duration of that duty period.

Performance indicators may also be established to measure the following:

  • difference between planned and actual flight hours;
  • difference between planned and actual duty hours;
  • difference between planned and actual number of days off;
  • number of unscheduled overnights; 
  • number of roster changes per scheduled seasonal period;
  • use of commander’s discretion;
  • changes of schedule carried out after published roster  

With regard to operator’s responsibilities, in particular operational robustness of rosters, we also recommend guidance material to ORO.FTL.110 developed by UK CAA.

View

Was this helpful?

Vote up  1
Vote down  0

Flying activities outside an AOC (see also ORO.FC.100): How will activities as an instructor or an examiner performed by an operating crew member in their free time be considered for the purpose of duty time and rest periods?

The purpose of Subpart-FTL is to ensure that crew members in commercial air transport operations are able to operate with an adequate level of alertness. It does not regulate the activities performed by crew members in their free time.

Nonetheless, it is the responsibility of crew members to make optimal use of the rest periods and to be properly rested so they will not perform duties when unfit due to fatigue.

A crew member in commercial air transport operations may be required to report to the operator his/her professional flying activities outside the commercial air transport operation to allow the operator to discharge its responsibilities (ORO.FTL.110) appropriately.

An operator should establish its policy with regard to crew members conducting these kinds of activities. 

View

Was this helpful?

Vote up  1
Vote down  0

Deviation from the applicable CS ORO.FTL.125 (c) (see also ARO.OPS.235): What does a deviation from the applicable CS mean or derogation from an implementing rule?

The flight time specification schemes of an individual operator (IFTSS) may differ from the applicable CS / IRs under strict conditions.

The operator has a number of steps to follow before implementing a deviation/derogation.

Additionally, the competent authority has a number of steps to follow before approving a deviating/derogating IFTSS.

All the steps are described in this Evaluation Form (link) developed by EASA to facilitate NAAs and operators in this process.

View

Was this helpful?

Vote up  0
Vote down  0

Flight time specification scheme for air taxi operations, (see also Articles 2 (6) and 8(2) of Regulation (EU) no 965/2012): An air taxi operator has both an aeroplane with less than 19 seats and one aeroplane with more than 20 seats. What FTL regulation shall the crew who is flying both types follow?

The operator implements Subpart ORO.FTL for its operations with aeroplanes of 20 seats or more. 

For air taxi operations with aeroplanes of 19 seats or less, the operator complies with EU OPS, Subpart Q.

However, the aim of the requirements is to ensure that crew members are able to operate at a satisfactory level of alertness. Fatigue accrued during an operation in one fleet might impact on the performance of a crew member when conducting a following flight in the other fleet. 

Therefore, from a fatigue management perspective, it makes sense to apply a common FTL scheme under Subpart ORO.FTL consistently to pilots in such operations. 

View

Was this helpful?

Vote up  0
Vote down  1

Approval of Individual Flight Time Specification Schemes (IFTSS), (see also ARO.OPS.235):

May a competent authority give ONE approval for an individual flight specification scheme to be used by three different operators with three AOCs?

No. Each operator needs its own approved individual flight time specification scheme.

View

Was this helpful?

Vote up  0
Vote down  1

Unknown state of acclimatisation GM1 ORO.FTL.205(b)(1): If the crew member is in an unknown state of acclimatisation, what is the reference time?

In that case, there is no reference time. For crew members in an unknown state of acclimatisation Table 3 in ORO.FTL.205 (b)(2) or Table 4 ibidem applies. These Tables do not contain any reference time.

View

Was this helpful?

Vote up  0
Vote down  0

Unknown state of acclimatisation ORO.FTL.205(b)(3): What are the daily FDP limits when crew members are in an unknown state of acclimatisation under fatigue risk management (FRM)?

Table 4 in ORO.FTL.205 (b)(3) establishes the limits of the maximum daily FDP when crew members are in unknown state of acclimatisation and the operator has implemented FRM.

View

Was this helpful?

Vote up  0
Vote down  0

Mixing FDPs extended without in-flight rest and FDP’s extended due to in-flight rest ORO.FTL.205 (d) ORO.FTL.205 (e): Is it possible to roster two extended FDPs without in-flight rest and one extended FDP with in-flight rest in 7 consecutive days?

Yes. The limit of two extensions of up to 1 hour in 7 consecutive days specified in ORO.FTL.205 (d) (1) only applies to the use of extensions without in-flight rest by an individual crew member.

View

Was this helpful?

Vote up  0
Vote down  0

Planned FDP extensions ORO.FTL.205(d): Must planned extensions be included in the operator’s roster?

Published duty rosters may or may not include extended FDPs.

However, FDPs extended in accordance with ORO.FTL.205 (d) must be planned and notified to crew members in advance i.e. allowing each crew member to plan adequate rest.

The time limit for notification of a planned extended FDP to an individual crew member need to be established by the operator in line with ORO.FTL.110 and specified in the OM-A.

View

Was this helpful?

Vote up  0
Vote down  0

Planned FDP extensions ORO.FTL.205(d) (see also ORO.FTL.105(1)): Can a crew member acclimatised to the local time of the departure time zone (‘B’ state), but not acclimatised to the local time where he/she starts the next duty (‘D’ state), be assigned a planned extended flight?

While it may be legal to roster an extended FDP (no in-flight rest) to a crew member who is not acclimatised to the local time where the actual duty starts, the actual operational environment may be such that it would be very fatiguing for a particular crew member to perform that FDP.

Although operations on an extended FDP are possible under ORO FTL.1.205(d), the operator still needs to comply with the fatigue management obligations stemming from ORO.FTL.110 and especially to ensure that the crew members are sufficiently rested to operate.

View

Was this helpful?

Vote up  0
Vote down  0

Commander’s discretion ORO.FTL.205(f): Do we need to use Commander’s discretion if actual FDP is going to last more than planned but less than the maximum daily FDP allowed?

No. If the actual FDP is less than the maximum allowed, commander’s discretion is not needed.

View

Was this helpful?

Vote up  1
Vote down  0

Commander’s discretion ORO.FTL.205(f): When should commander’s discretion be used?

Commander’s discretion may be used to modify the limits on the maximum daily FDP (basic or with extension due to in-flight rest), duty and rest periods in the case of unforeseen circumstances in flight operations beyond the operator’s control, which start at or after the reporting time.

Considering the ICAO definition of ‘unexpected conditions’, unforeseen circumstances in flight operations for the purpose of ORO.FTL.205(f) are events that could not reasonably have been predicted and accommodated, such as adverse  weather, equipment malfunction or air traffic delay, which may result in necessary on-the-day operational adjustments.

Commanders cannot be expected to exercise discretion without an understanding of the events that constitute unforeseen circumstances. It is therefore necessary that they receive appropriate training on the use of commander’s discretion along with how to recognize the symptoms of fatigue and to evaluate the risks associated with their own mental and physical state and that of the whole crew.
Operators should ensure that sufficient margins are included in schedule design so that commanders are not expected to exercise discretion as a matter of routine

View

Was this helpful?

Vote up  7
Vote down  1

Commander’s discretion ORO.FTL.205(f), (see also ORO.FTL.205 (d)): 1. What is the maximum FDP extension allowed under commander’s discretion? 2. How would commander’s discretion apply when the FDP of a non-augmented crew has already been extended in accordance with ORO.FTL.205 (d))?

1. Up to 2 hours for two pilot crew and up to 3 hours for augmented crew.

2. For a two pilot extended FDP operation, the use of commander’s discretion is always based on the maximum daily FDP table ORO.FTL.205 (b) (1).

For example, when 1 hour has already been added to the maximum daily FDP in accordance with ORO.FTL.205 (d), then only 1 hour is left for commander’s discretion.

 

View

Was this helpful?

Vote up  1
Vote down  0

Commander’s discretion ORO.FTL.205(f): Referring to commander’s discretion, do I need to consider the reporting time and number of sectors?

Yes. The commander needs to consider the actual number of sectors that the crew members will complete as this may be different from the plan. This FDP calculation would be based on the time the crew member actually reported.

View

Was this helpful?

Vote up  0
Vote down  0

Conversion/line checks Post flight duty ORO.FTL.210: How should briefings and debriefings during conversion/line checks be accounted for?

In accordance with the definition of duty, conversion/line training is duty.

Any duty (including the briefing and debriefing for training purposes) after reporting for a duty that includes a sector or a series of sectors until the aircraft finally comes to rest and the engines are shut down, at the end of the last sector on which the crew member acts as an operating crew member, is considered flight duty period.

Post flight duties, on the other hand (including debriefings also for training purposes), are considered as duty period.

View

Was this helpful?

Vote up  0
Vote down  0

Post-flight duty AMC1 ORO.FTL.210(c): What should the operator do if the actual post flight duty time is longer than the established time in the OM?

The operator needs to implement a monitoring system to ensure that the minimum time period for post-flight duties is adequate since rest or shortened rest could potentially impact fatigue.

The commander or a cabin crew member should inform the operator where the post-flight duties have taken longer than planned and this is then accounted for in duty and rest periods.

View

Was this helpful?

Vote up  2
Vote down  1

Positioning for purposes other than operating ORO.FTL.215 (b): How should time spent to travel from the place of rest or home base to a simulator (when outside the base) be taken into account?

The time spent to travel from a place of rest or home base to a simulator, at the request of the operator, counts as a duty period.

Any transfer of a non-operating crew member from one place to the other at the request of the operator is called positioning and is counted as a duty period.

Travel from a crew member’s private place of rest to the reporting point at home base and vice versa, and local transfers from a place of rest to the commencement of duty and vice versa are travelling, but not positioning, and so not counted as duty period.

View

Was this helpful?

Vote up  1
Vote down  0

Positioning ORO.FTL.215: Does positioning begin when the crew member arrives at the airport/train station or when the aeroplane/train leaves?

Positioning begins after reporting at the designated reporting point.

The operator should publish reporting times taking into account the time necessary for completing the travelling procedures depending on the mode of transportation (e.g. registration of passengers and baggage, security checks, etc.).

First example: Crewmember 1 is required to position from A to B on the commercial flight of an airline other than the airline which Crewmember 1 is flying for. This commercial flight is departing at 10:00, but airport A is an international airport and the time necessary for passenger and baggage registration and security checks is 2h before departure time. In this case, the positioning begins 2h before departure time.  

Second example: Crewmember 2 is required to position from A to B on a high speed train. This train is departing at 10:00 and the time necessary for passenger and baggage registration and security checks is 15 minutes before departure time. In this case, the positioning begins 15min before departure time.

View

Was this helpful?

Vote up  1
Vote down  0

Positioning ORO.FTL.215: Shall a positioning between active sectors count as a sector for a pilot or cabin crew?

No, any positioning within an FDP does not count for the sector calculation of the FDP limit but counts towards the FDP.

View

Was this helpful?

Vote up  0
Vote down  0

Split duty ORO.FTL. 220: Is it possible to have more than one split duty within one FDP?

No. ORO.FTL.220 provides for a break on the ground which implies a single break on the ground, for the purpose of extending the basic daily FDP.

If an operator wishes to schedule more than one break on the ground within one FDP, for the purpose of extending that FDP, it must apply for a derogation from ORO.FTL.220.

Derogations must follow the procedure of Article 14(6) of Regulation 216/2008. A final decision on a derogation from the implementing rules is made by the European Commission.

View

Was this helpful?

Vote up  1
Vote down  0

Standby ORO.FTL.225(a) (see also CS FTL.1.225 and GM1 CS FTL.1.225(a)): Can a standby be finished before the planned “end time notified in advance”, after a notification during the standby (saying that there will be no assignment) and the rest period be initiated at the time of the notification of the new standby end?

Yes. According to ORO.FTL.225 (a), a time period with a start and end time, during which a crew member must be available to be contacted to receive an assignment, must be defined.

A crew member may, during the standby period, be notified that standby has ceased. CS FTL.1.225 establishes further conditions.

GM1 CS FTL.1.225 (a) explains that a minimum rest period according to ORO.FTL.235 should be provided after the notification of the revised end of the standby period.

View

Was this helpful?

Vote up  1
Vote down  0

Reserve ORO.FTL.230: Can a reserve, during which no flight was assigned, be considered as a day off afterwards?

No, a reserve period that does not result in a duty period may not retrospectively be considered as part of a recurrent extended recovery rest period.

View

Was this helpful?

Vote up  0
Vote down  0

Rest prior to an FDP ORO.FTL.235 (a): If a crew member with office duties spends one day in the office, what should be the duration of the rest before his/her reporting for an FDP?

The minimum rest period at home base before undertaking an FDP shall be in accordance with ORO.FTL.235 (a) (1) and (2).

Time spent at the office is duty time in accordance with ORO.FTL.105 (10).

View

Was this helpful?

Vote up  0
Vote down  0

Rest prior to a duty other than FDP ORO.FTL.235 (a): What is the duration of the rest period prior to a duty without FDP?

The term ‘minimum rest period’ under the Regulation (EU) No 965/2012 is only used for the recovery period before an FDP.

Otherwise, it is an off-duty period. The Regulation does not contain requirements for off-duty periods prior to a duty without FDP.

Example: FDP1 – off duty – DP1 – off duty – DP2 – rest – FDP2.

Nevertheless, the operator needs to be able to demonstrate they have considered the fatiguing nature and cumulative effects of these duty periods under their operator responsibilities as they can generate fatigue that could affect crew member’s ability to rest prior to his/her next FDP.

Also, the national law of the Member State regarding working time (as required by Council Directive 2000/79/EC) would be applicable and should be reviewed as it may contain minimum rest periods for crew members based in that Member State.

View

Was this helpful?

Vote up  0
Vote down  0

Reduction of recurrent extended recovery rest by commander’s discretion ORO.FTL.235(d) (see also ORO.FTL.205(f)): Can the extended recovery rest period be reduced with commander’s discretion?

No, commander’s discretion cannot be applied to an extended recovery rest period

View

Was this helpful?

Vote up  1
Vote down  0

Increase of interval between two recurrent extended recovery rest periods by commander’s discretion ORO.FTL.235(d) (see also ORO.FTL.205(f)): May the crew member exercise his/her discretion to finish back at home base exceeding the 168 hours’ time between two extended recovery rest periods? For example, a crew member is planned to finish his last FDP flying back to home base, two hours prior to reaching 168 hours. There is a departure delay which occurred after reporting. As a result, the crew member would exceed the 168 hours by 1 hour.

No. Extension of the 168 hours between two recurrent extended recovery rest periods is not allowed. 

The operator must better plan duties and rest times. The Regulation does not say that exactly 168 h must be reached; they are not a target, they are a maximum threshold.

View

Was this helpful?

Vote up  0
Vote down  0

Increase of interval between two recurrent extended recovery rest periods ORO.FTL.235(d): Can the 168h limit between two extended recovery rest periods be extended? For example, a crew member reports at Paris on Monday at 7am and ends a series of flights in Singapore, on Sunday, at 8 pm; he/she should be given his/her extended recovery rest period in Singapore, but might be willing to come back to his/her base, hence infringing the 168h limit through positioning.

No. The 168h limit between two extended recovery rest periods can only be extended through a derogation from ORO.FTL.235 (d).  

Derogation from the implementing rules is possible under Article 14 of Regulation (EC) 216/2008. 

View

Was this helpful?

Vote up  0
Vote down  0

Re-planning of recurrent extended recovery rest period ORO.FTL.235 (d): Is re-planning of a recurrent extended recovery rest period allowed and when?

Yes. This is provided that re-planning of rest is completed and notified before the rest period has started and the re-planning practices do not conflict with a crew member’s opportunity to plan adequate rest as required by ORO.FTL.110 (a).  

In any case, the time between the end of one recurrent extended recovery rest period and the beginning of the next recurrent extended recovery rest period cannot be more than 168 hours.

Operator’s procedures for re-planning should describe by which means the opportunity for crew members to plan adequate rest is provided in the case of re-planning.

View

Was this helpful?

Vote up  0
Vote down  0

Record keeping ORO.FTL.245: Do records required in ORO.FTL.245 have to reflect planned or actual FDP, DP and rest?

Planned rosters may differ substantially from achieved rosters. 

In order to ensure appropriate oversight of FTL by the competent authority, operators need to maintain (for a period of 24 months) records of the actual values of flight times, FDP, rest periods and days free of all duties. 

According to AMC1 ORO.FTL.110 (j) on operational robustness operators should establish and monitor performance indicators for operational robustness rosters. 

This can only be done if operators keep records of both, planned and achieved rosters.

View

Was this helpful?

Vote up  0
Vote down  0

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

Our employer does not provide individual records of the time spent for e-learning and for certain administrative tasks such as visa renewal.

View

Was this helpful?

Vote up  0
Vote down  0

Home base change CS FTL.1.200(b): Is it correct to understand that if a crew member is asked to report for an FDP at a reporting point other than his/her home base without extension of his/her recurrent extended recovery to 72h incl. 3 local nights, immediately prior to that FDP, the home base has not been changed for the purpose of Subpart FTL?

Yes. In such case, the requirements for reporting out of home base apply.

View

Was this helpful?

Vote up  0
Vote down  0

Consecutive night duties CS FTL.1.205(a)(1): What does ‘consecutive’ mean in the context of the requirements and limits of CS FTL.1.205?

‘Consecutive’ is referring to two night duties only separated by a rest period. 

Two night duties would not be considered as ‘consecutive’, if there is a recurrent extended recovery rest period between them or if they are separated by rest periods surrounding a non-night duty

View

Was this helpful?

Vote up  0
Vote down  3

Night duties CS FTL.1.205(a)(2), (see also GM1 CS FTL1.205 (a)(2)): Is it necessary to have an ‘approved’ FRM to operate long night duties (FDP over 10hrs)?

No, for night duties of over 10 hours an appropriate fatigue risk management applies. Guidance for that is provided in GM1 CS FTL1.205 (a) (2).

A FRM compliant with ORO.FTL.120 is only required in two cases: reduced rest and crew members in unknown state of acclimatisation on a longer FDP.  

Additionally, the approval of FRM is not a stand-alone approval. FRM, if required, is approved as a constituent part of the IFTSS approval.

View

Was this helpful?

Vote up  0
Vote down  0

In-flight rest CS FTL.1.205(c) : Is it possible to extend the FDP, if not all pilots get an in-flight rest?

CS FTL.1.205(c)(1)(ii) specifies that, for the purpose of FDP extension, each crew member needs to have an in-flight rest period.

First example where an extension of the FDP due to in-flight rest is possible: 

Pilot 1 and Pilot 2 commence a FDP from A to B (1:30 h sector). When arriving at B, a third pilot (Pilot 3) joins the crew and they fly from B to C (11 h sector). 

The length of the flight from B to C allows each crew member on board (pilots 1, 2 & 3) to have the minimum in-flight rest period during cruise phase: 2 consecutive hours for the flight crew members at control during landing and consecutive 90-minute period for the third pilot. 

Second example, where an extension of the FDP due to in-flight rest is not possible: 

Pilot 1 and Pilot 2 commence a FDP from A to B (7 h sector). When arriving at B, a third pilot (Pilot 3) joins the crew and they fly from B to C (5 h sector).
 
The length of the flight from B to C does not allow each crew member on board (pilots 1, 2 & 3) to have the minimum in-flight rest period during cruise phase: 2 consecutive hours for the flight crew members at control during landing and consecutive 90-minute period for the third pilot.

View

Was this helpful?

Vote up  0
Vote down  1

Maximum daily FDP with the use of extensions due to in flight rest CS FTL.1.205(c)(2): Why does the ‘maximum daily FDP with the use of extensions due to in flight rest’ not take into account the start of FDP at reference time?

An extended duty period will usually involve operating during the WOCL. The in-flight rest opportunity during the WOCL mitigates the absence of reduction of the FDP based on the reference time. 

The limits of CS FTL.1.205(c) (2) are therefore irrespective of the WOCL of crew members, on the condition that the minimum flight crew is augmented and in-flight rest facilities, meeting certain standards, are available to provide recuperative sleep

View

Was this helpful?

Vote up  0
Vote down  0

Delayed reporting CS FTL.1.205(d)(1): Is it possible to inform crew members of a delay without giving the new reporting time?

No. An actual reporting time must be given when the crew member is informed that the delayed reporting procedure is activated.

If an operator does not have a delayed reporting procedure, then it can’t be used.

View

Was this helpful?

Vote up  0
Vote down  0

Delayed reporting CS FTL.1.205(d)(1)(iii): Why does delayed reporting with a delay of less than 4 hours not account for the WOCL? Is there any scientific evidence for this?

There is no scientific evidence, on the basis of which a delay of less than 4 hours does not take the WOCL into account.
 
In any case, operator’s procedures on delayed reporting should avoid or minimise the negative effect of WOCL encroachment.
 
Importantly, the maximum FDP will never become longer due to a delayed reporting time:
 
  • If the delay is less than 4 hours – the maximum FDP as originally planned, remains the same. 
  • If the delay is more than 4 hours – the maximum FDP will be shorter than the originally planned FDP, because the delayed reporting time has a limiting effect on it.
Procedures for delayed reporting must be described in the OM, including a notification time that allows the crew member to continue his/her rest when the delayed reporting procedure is activated. 
 
A delayed reporting procedure may be triggered by the operator, while the crew member is still at home or in the suitable accommodation facility, when prior to the beginning of a flight duty period an unforeseen event occurs which will delay the planned flight departure.
View

Was this helpful?

Vote up  0
Vote down  0

Split duty (see also ORO.FTL.205 (b)(2) and ORO.FTL.220): Can split duty be scheduled when crew members are in an unknown state of acclimatisation?

Yes, but any extension of the FDPs limits in Table 3 of ORO.FTL.205 (b)(2) falls under the requirement for a FRM.

View

Was this helpful?

Vote up  0
Vote down  0

Split duty CS FTL.1.220 (b): Are the 30 minutes for post and pre-flight duties as well as travelling counted in total or 30 min for post flight duties, 30 min for travelling after post flight duties, 30 min for travelling before pre-flight duties and 30 min for pre-flight duties?

CS FTL.1.220 (b) instructs the operator to specify actual times for post and pre-flight duties and for travelling in its operations manual. The minimum for the total is 30 minutes. 

The operator must demonstrate how travelling in both directions, and post and pre-flight duties are accomplished in the time defined in the OM.

View

Was this helpful?

Vote up  0
Vote down  0

Split duty CS FTL.1.220(d): Should suitable accommodation be provided for a split duty?

CS FTL.1.220 (b) instructs the operator to specify actual times for post and pre-flight duties and for travelling in its operations manual. The minimum for the total is 30 minutes. 

The operator must demonstrate how travelling in both directions, and post and pre-flight duties are accomplished in the time defined in the OM.
Suitable accommodation as defined in ORO FTL 105 (4) is required to be provided for a break of 6 hours or more or for a break that encroaches the WOCL.

View

Was this helpful?

Vote up  0
Vote down  0

Rest after airport standby or other-standby CS FTL.1.225 (a)(1)& CS FTL.1.225 (b)(4): What is the basis for rest calculation after a standby followed by an FDP? Is it the reporting time for standby or the “actual reporting time” for the assigned FDP?

The minimum rest period depends on the length of previous duty. 

Airport standby counts as duty for the purpose of ORO.FTL.235. Therefore the rest calculation after airport standby followed by an FDP is based on the reporting time for that standby. This also applies to airport duty.

Other standby does not count as duty for the purpose of rest (it counts partly as duty for the purpose of ORO.FTL.210 only). Therefore the rest calculation after other-standby followed by an FDP is based on the reporting time for the assigned FDP

View

Was this helpful?

Vote up  0
Vote down  0

Airport standby CS FTL.1.225 (a)(2)(ii): Why does CS FTL.1.225 (a)(2)(ii) not stipulate the maximum duration of airport standby?

The maximum duration of airport standby is defined indirectly by the limits of the combined duration of airport standby and FDP.

View

Was this helpful?

Vote up  0
Vote down  0

Airport standby CS FTL 1.225(a)(2)(ii), (see also ORO.FTL.205 (b)&(d); CS FTL 1.205 (a) (2)): We understand that the limit of 16 hours is not applicable when airport standby is followed by a FDP with in-flight rest. Does that mean that there is no limit for that kind of situation?

Yes, there is no limit. 
The limit of 16 hours only applies to basic maximum daily FDPs without in-flight rest under ORO.FTL.205 (b) and to extended daily FDPs without in-flight rest under ORO.FTL.205 (d).

Furthermore, the operator applies appropriate fatigue risk management to actively manage the fatiguing effect of night duties of more than 10 hours in relation to the surrounding duties and rest periods

View

Was this helpful?

Vote up  0
Vote down  0

Other-standby followed by an FDP CS FTL.1.225(b)(2): How shall an operator expect a crew member to use whole or part of a standby for sleep when there are disturbance factors like difficulty to fall asleep, disturbed sleep due to sick children, waking-up by external noise, etc.?

According to CS FTL.1.225 (b)(2), the operator designs its standby procedures in a certain way. The expectation is on the design of the procedure by the operator, not on the individual crew member. 

The expectation on the crew member is to follow the procedure to the best of his/her abilities and in good faith at all times.

View

Was this helpful?

Vote up  0
Vote down  0

Awake time CS FTL 1 225 (b)(2): Who is responsible for making sure that the 18h are not exceeded? The crew member or the operator? Can the operator fully transfer the responsibility to the crew member?

The operator is only required to have established such procedures (control mechanisms) so as to prevent situations where the combination of standby and FDP would lead to more than 18 hours awake time.

18 hours awake time is mentioned in the context of the combination of other-standby prior to an FDP and the FDP itself. A simple mathematical equation between the sum of the standby time and FDP, on the one hand, and the time awake on the other, is not possible to do, because the start time of the awake period is an unknown value i.e. the operator may be unable to verify how long a crew member has been awake. 

It is reasonable for the operator to expect crew members to manage their rest and sleep opportunities during pre-duty rest periods and while on standby in order to be able to perform FDP.

The procedure and expectation for the crew to rest appropriately during their standby should also be included when training crew on FTL and fatigue management.
The following are examples of what an operator should consider when designing procedures:

  • the duties and rest periods prior to the scheduled standby;
  • the time of the day in which the rest period prior to the scheduled standby occurs; 
  • a minimum of 8 hours’ sleep opportunity before or within the scheduled standby, during which the crew member is not disturbed;
  • the length of the standby and the subsequent FDP;
  • the time for post flight duties and for travelling to the suitable accommodation if away from home base;
  • provision of training and advice to crew members

The NAAs are responsible for verifying that the above procedures have been established and are effective.

View

Was this helpful?

Vote up  0
Vote down  0

Other-standby CS FTL.1.225(b)(2), (see also CAT.OP.MPA.210(a)(3)): Would using a controlled rest procedure while the flight crew member is at his/her assigned station break the 18-hour awake time?

No. Controlled rest procedure is a countermeasure to manage unexpected fatigue, whilst the 18-hour awake time target is part of the operator roster planning procedures. 

According to CAT.OP.MPA.210 (a)(3) controlled rest organised by the commander, if workload permits, shall not be considered to be part of a rest period for purposes of calculating flight time limitations nor used to justify any extension of the duty period.

Under CS FTL.1.225 (b)(2), the operator designs standby procedures in a way that makes unexpected fatigue unlikely by avoiding excessive awake times. 

The frequent use of controlled rest after having been called from other-standby could indicate that the standby procedure does not fulfil the expectation to avoid excessive awake times. 

Controlled rest procedure to manage unexpected fatigue should be described in the operations manual. (ref. AMC3 ORO.MLR.100).

The operator should be able to monitor the use of controlled rest to evaluate effectiveness of mitigation strategies.

View

Was this helpful?

Vote up  0
Vote down  0

Other-standby CS FTL.1.225(b)(3): How is the time spent on other-standby before an assignment accounted for?

According to CS FTL.1.225 (b) (3), 25% of time spent on other-standby counts as cumulative duty.

View

Was this helpful?

Vote up  1
Vote down  0

Other-standby CS FTL.1.225 (b), (see also ORO.FTL.105 (25)): Is it possible during other-standby to assign an FDP with a reporting time after the scheduled end of that standby period has elapsed?

Under review.

View

Was this helpful?

Vote up  0
Vote down  3

Other-standby modified to airport standby CS FTL.1.225, (see also ORO.FTL.105 (25)): Can other-standby be modified to airport standby during the standby? For example, can a pilot on home standby be required to go to the airport to continue on airport standby? What limits must be used?

Yes. During a standby period any duty may be assigned (ORO.FTL.105 (25)). That includes airport standby or duty at the airport. 

Limits for assignment of airport standby after home standby are not explicitly mentioned in CS FTL.1.225. 

The assignment of airport standby is considered as airport duty and the subsequent FDP counts from the airport reporting time as stated in ORO.FTL.225 (d). 

If the other-standby lasts less than 6 hours, the maximum FDP counts from reporting for the airport standby. If the other-standby lasts more than 6 hours, a reduction is applicable to the subsequent FDP.

If an FDP is assigned during the airport standby, the combination of home standby and FDP does not lead to more than 18 hours awake time.

View

Was this helpful?

Vote up  0
Vote down  0

Reserve and other-standby CS FTL.1.230: While a crew member is on reserve, can his/her assignment be changed and continue as a home standby?

No, but the crew member can be assigned a home standby after the end of the reserve period.

View

Was this helpful?

Vote up  0
Vote down  0

Reserve CS FTL 1.230(b): Is there any rest requirement after a reserve period, if there is no assignment of duty period during the reserve?

Reserve times do not count as duty period for the purpose of ORO.FTL.210 and ORO.FTL.235. 

That means that there is no requirement for a minimum rest period after reserve, if no duty has been assigned.

View

Was this helpful?

Vote up  0
Vote down  0

Reserve CS FTL.1.230 (d): Is it necessary to have an FRM to protect an 8-hour sleep opportunity during reserve?

No.  Operators are however encouraged to apply appropriate fatigue risk management techniques to be able to fulfil their responsibilities under ORO.FTL.110. 

The techniques described in the ICAO Fatigue Management Guide for Airline Operators may be useful reference to assist operators developing their approach.

View

Was this helpful?

Vote up  0
Vote down  0

Reserve CS FTL 1.230(d): Should the period of 8 hours run consecutively or is it possible to break it in two different periods?

The period of 8 hours consists of 8 consecutive hours.

View

Was this helpful?

Vote up  0
Vote down  0

Rest between disruptive schedules CS FTL.1.235(a)(1), (see also ORO.FTL.105(8)): The rule for transition between late finish/night duty and early start says that the rest between the FDPs needs to include a local night. Does this mean that the rule only applies if the late finish/night duty and the early duty are FDP’s?

It depends on the type of the early duty following a late or night duty.

If an early duty is a standby or a duty at the airport that leads to an FDP, then the rest period before that early duty must include a local night. 

Otherwise, the rest period between the 2 other duties or between a FDP and other duty (e.g. night training in a simulator) does not need to include 1 local night. 

Nevertheless, Subpart FTL provides a system of measures which jointly act to reduce the risk of increased fatigue and reduced alertness and performance levels of crew members, and to mitigate the acute disruption of the sleep pattern in the case of disruptive schedules.

For example, the operator must avoid practices that cause a serious disruption of an established sleep/work pattern, such as alternating day/night duties (ORO.FTL.110).
 

View

Was this helpful?

Vote up  0
Vote down  0

Rest compensation for time zone differences CS FTL.1.235(b)(3)(i): How should we count the time elapsed (h) since reporting for the first FDP in a rotation involving at least 4 hour time difference to the reference time?

Elapsed time (h) should be counted from the first FDP including at least 4 hour time difference to the reference time, as the rest compensation for time zone differences is given when the crew becomes affected by the time zone differences. 

View

Was this helpful?

Vote up  0
Vote down  0

Reduced rest CS FTL.1.235(b)(3)(ii), (see also ORO.FTL.235 (c) and (e)): Is it possible to reduce the 14h rest away from home base following an FDP involving a 4-hour time difference or more?

No. CS FTL.1.235 (b)(3)(ii) does not foresee a reduction of the 14h rest away from home base to compensate for time zone crossing.

ORO.FTL.235 (c) describes the conditions under which the minimum rest periods according to ORO.FTL.235 (a) and (b) may be reduced.

ORO.FTL.235 (e) establishes the rest periods to compensate the effects of time zone crossing.

Additional rest periods to compensate the effects of time zone crossing shall be specified in flight time specification schemes.

View

Was this helpful?

Vote up  0
Vote down  0

Rest to compensate for time zone differences CS FTL.1.235(b)(4): What does Eastward-Westward or Westward-Eastward transition mean?

For the purpose of CS FTL.1.235 (b) (4), ‘Eastward-Westward and Westward-Eastward transition’ means the transition at home base between a rotation in one direction and a rotation in the opposite direction, each involving a 4-hour time difference or more. 

At least 3 local nights of rest at home base are provided between such alternating rotations.

However, irrespective of where the transition occurs - at home base or away from home base, the operator, using safety risk management processes, should monitor rotations in opposite directions in terms of their impact on crew members’ circadian rhythm and fatigue, and provide sufficient rest to crew members between such rotations. 

View

Was this helpful?

Vote up  0
Vote down  0

Monitoring Time Zone Differences CS FTL.1.235(b)(5): Does the requirement to monitor combinations of rotations require FRM in accordance with ORO.FTL.120?

No. FRM is not required. However, CS FTL.1.235 (b)(5) requires that fatigue risks arising from combinations of rotations be monitored under the operator’s management system. 

The techniques described in the ICAO Fatigue Management Guide for Airline Operators (associated to ICAO Doc 9966) may be useful reference to assist operators developing their approach.

View

Was this helpful?

Vote up  0
Vote down  0

Reduced rest CS FTL.1.235(c)(5): Is it possible to apply reduced rest to two consecutive rest periods?

Yes. Up to 2 reduced rest periods in any 168 hours are allowed. They may be consecutive.

Reduced rest is only possible under FRM, as part of an approved IFTSS.

View

Was this helpful?

Vote up  1
Vote down  0

Cabin Crew

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. EASA is actively working with the European Member States and with the International Civil Aviation Organisation (ICAO) Cabin Safety Group (ICSG) on finding a solution that would facilitate a global mutual recognition of child restraint devices for infants and children amongst States and airlines. 

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 the use and types of child seats on board.

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

Commission Regulation (EU) No 965/2012 on air operations, Annex IV – Part-CAT:

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 less than 5700 kg and with an MOPSC of less than nine, 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;

 …….

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 by the competent authority on the basis of a technical standard and marked accordingly;

(2) CRDs approved for use in motor vehicles according to the UN standard ECE R 44, -03 or later series of amendments;

(3) CRDs approved for use in motor vehicles and aircraft according to Canadian CMVSS 213/213.1;

(4) CRDs approved for use in motor vehicles and aircraft according to US FMVSS No 213 and manufactured to these standards on or after 26 February 1985. US approved CRDs manufactured after this date must bear the following labels in red letters:

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

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

(5) CRDs qualified for use in aircraft according to the German ‘Qualification Procedure for Child Restraint Systems for Use in Aircraft’ (TÜV Doc.: TÜV/958-01/2001); and

(6) devices approved for use in cars, manufactured and tested to standards equivalent to those listed above. The device 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.

(c) Location

(1) Forward-facing CRDs 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 CRDs should only be installed on forward-facing passenger seats. A CRD 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 in a CRD should be located as near to a floor level exit as feasible.

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

(4) An infant 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 are from the same family or travelling group provided the infants are accompanied by a responsible adult sitting next to them.

(6) A row segment is the fraction of a row separated by two aisles or by one aisle and the aeroplane fuselage.

(d) Installation

(1) CRDs should only be installed on a suitable aeroplane seat with the type of connecting device they are approved or qualified for. For instance, CRDs to be connected by a three point harness only (most rearward-facing baby CRDs currently available) should not be attached to an aeroplane seat with a lap belt only; a CRD designed to be attached to a vehicle seat only by means of rigid bar lower anchorages (ISO-FIX or US equivalent), should only be used on aeroplane seats that are equipped with such connecting devices and should not be attached by the aeroplane seat lap belt. The method of connecting should be the one shown in the manufacturer’s instructions provided with each CRD.

(2) All safety and installation instructions should be followed carefully by the responsible adult accompanying the infant. Cabin crew should prohibit the use of any inadequately installed CRD or not qualified seat

(3)  If a forward-facing CRD with a rigid backrest is to be fastened by a 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 CRD 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 CRD is adjustable in recline, it must be in an upright position for all occasions when passenger restraint devices are required.

Extract from the 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 means ‘child restraint system’.

View

Was this helpful?

Vote up  2
Vote down  0

Medical fitness

Is Cabin Crew Member required to carry his/her medical certificate when on duty?

Reference: Regulation (EU) No 1178/2011 Aircrew, Annex IV Part-MED and ED Decision 2011/015/R are available on EASA website. 

EU legislation does not contain any provisions on the carriage of a medical report when on duty. MED.C.030(a)(2) requires cabin crew members to provide the related information of their medical report or the copy of their medical report to the operator(s) employing their services. MED.C.030(b) requires the cabin crew medical report to indicate the date of the aero-medical assessment, whether the cabin crew member has been assessed fit or unfit, the date of the next aero-medical assessment and, if applicable, any limitation(s). Any other elements shall be subject to medical confidentiality in accordance with MED.A.015.

Cabin crew members are encouraged to carry their medical report or a copy while on duty to attest their medical fitness and limitation(s). The operator may also have procedures in place through which a cabin crew member’s medical report can be readily available upon request by a competent authority.

 

View

Was this helpful?

Vote up  13
Vote down  0

Decrease of medical fitness and an ‘unfit’ medical report.

Reference: Regulation (EU) No 1178/2011 Aircrew, Annex IV Part-MED and ED Decision 2011/015/R are available on EASA website.

In case of a decrease in cabin crew member’s medical fitness, the cabin crew member shall, without undue delay, seek the advice of an aero-medical examiner or aero-medical centre or, where allowed by the Member State, an occupational health medical practitioner who will assess the medical fitness of the individual and decide if the cabin crew member is fit to resume his/her duties.

In case a cabin crew member has been assessed as ‘unfit’, the cabin crew member has the right of a secondary review. The cabin crew member shall not perform duties on an aircraft and shall not exercise the privileges of their cabin crew attestation until assessed as ‘fit’ again.

View

Was this helpful?

Vote up  2
Vote down  2

Where can I find the EU medical requirements for Cabin Crew?

References:  (are available on EASA website)
Regulation (EU) No 1178/2011 Aircrew, Annex IV Part-MED.
ED Decision 2011/015/R.

NOTE: This FAQ only provides an overview of the areas covered by the individual subparts A, C and D of the regulation. The medical requirements for cabin crew are extensive in text, therefore to find the exact aspect you are looking for, we recommend that you directly refer to the respective subpart of the regulation.

Regulation (EU) No 1178/2011 Annex IV: Part-MED:

  • Subpart A, Section 1: general requirements, such as competent authority, scope, definitions, medical confidentiality, decrease in medical fitness and obligations of medical doctors conducting the aero-medical assessment of cabin crew;
  • Subpart C, all three Sections: requirements  for medical fitness of cabin crew;
  • Subpart D,
    • Section 1: Aero-medical examiners (AEM);
    • Section 3: Occupational Health Medical Practitioners (OHMP), the requirements for the medical doctors who conduct aero-medical assessment of cabin crew. Please note that general medical practitioners (GMP) (Section 2) may not conduct aero-medical assessment of cabin crew.

ED Decision 2011/015/R contains acceptable means of compliance (AMC) and guidance material (GM) which complement the rules. The AMC and GM specify the detailed medical conditions and the related medical examinations or investigations.

View

Was this helpful?

Vote up  0
Vote down  2

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).   

 

View

Was this helpful?

Vote up  5
Vote down  1

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

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).   

View

Was this helpful?

Vote up  10
Vote down  1

Practical ‘raft’ training

Why does Initial training under Part-CC require practical ‘raft’ training even if the operator’s aircraft is not equipped with slide rafts or life rafts?

Reference: Regulation (EU) No 1178/2011 Aircrew as amended by Regulation (EU) No 290/2012 Part-CC available on EASA website.

Under EU-OPS, practical training on the use of rafts was required during Initial training. EU-OPS was a regulation directed, and applicable, to operators, therefore, an operator could provide raft training only when cabin crew member was to actually  operate on the operator’s aeroplane fitted with rafts or similar equipment. The training was conducted with that operator’s specific equipment/rafts.

The Initial training under Regulation (EU) No 1178/2011, Part CC is no longer ‘operator-related’, it is generic, therefore, the practical training on rafts or similar equipment and an actual practice in water are not specific to an operator’s equipment. 

CCA holders, when recruited by an operator, are expected to have the ability to perform all types of cabin crew duties, including ditching related duties in water. Part-CC Cabin Crew Attestation (CCA) is issued for a life time and is recognised across all EU. Unlike the EU OPS Attestation, the CCA is subject to validity to attest the competence of the individual cabin crew member. This is foreseen in the Basic Regulation (Regulation (EC) No 216/2008) taking into account the increasing mobility of personnel in the aviation industry and the need to further harmonise cabin crew qualifications.

An operator may be granted an approval to provide Part-CC Initial training and to issue the CCA (entitled to a mutual recognition across the EU). That operator no longer acts as an operator training only its own cabin crew for its specific operations. That operator acts as a training organisation training future cabin crew who, in their life time, may also operate with other operators and in other Member States. 

 

View

Was this helpful?

Vote up  5
Vote down  0

Fire and smoke training

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

References:  (all are available on EASA website)
Regulation (EU) No 1178/2011 Aircrew as amended by Regulation (EU) No 290/2012.
Regulation (EU) No 965/2012 Air Operations.
ED Decision 2014/017/R containing AMC and GM to the rules.

NOTE: The requirements on fire and smoke training are extensive in text, therefore to have a better view and understanding, this FAQ should be read together with the rule text. The relevant rule reference is included in each line (type of training) below. 

1. Initial training:

  • CC.TRA.220 Initial training course and examination
  • Appendix 1 to Part-CC Initial training course and examination / Training programme;
    Point 8 on Fire and Smoke training
    Regulation (EU) No 290/2012, Annex V Part-CC.

2. Aircraft type training:

  • ORO.CC.125 Aircraft type specific and operator conversion training
    Reference: Regulation (EU) No 965/2012
  • AMC1 ORO.CC.125(c) and AMC1 ORO.CC.125(d) containing a training programme for aircraft type specific training and operator conversion training respectivel
    Reference: ED Decision 2014/017/R

3. Recurrent training:

  • ORO.CC.140 Recurrent training
    Reference: Regulation (EU) No 965/2012
  • AMC1 ORO.CC.140 Recurrent training
    Reference: ED Decision 2014/017/R

4. Refresher training’:

  • ORO.CC.145 Refresher training
    Reference: Regulation (EU) No 965/2012
View

Was this helpful?

Vote up  1
Vote down  0

Aircraft type training

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?

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

Aircraft type specific training and operator conversion training is not transferable from one operator to another as each operator may have its own customised aircraft cabin configurations incl. differences in safety and emergency equipment and standard operating and emergency procedures. Therefore, as required by ORO.CC.125, cabin crew members must complete Aircraft type specific training and operator conversion training before being assigned to operate on the operator’s aircraft.

View

Was this helpful?

Vote up  11
Vote down  1

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

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

Aircraft type specific training and operator conversion training is a requirement directed to operators as specified in ORO.GEN.005, therefore the operator is responsible for this training. However, an operator may contract out some activities (e.g. training) as specified in ORO.GEN.205 complemented by AMC1 ORO.GEN.205 and GM1 ORO.GEN.205 and GM2 ORO.GEN.205. Therefore, CCTO can only provide Aircraft type specific training and operator conversion training if contracted by an operator to do so. The operator remains responsible for this training and for the competence of its cabin crew.

View

Was this helpful?

Vote up  7
Vote down  0

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?

Reference: Regulation (EU) No 965/2012 Air Operations and the associated ED Decisions are available on EASA website.

The minimum number of cabin crew for an aircraft type, as determined by certification and approved by EASA, is stated on the Type Certification Data Sheet. The minimum number of cabin crew and the evacuation procedures form part of the Operations Manual. Reducing the minimum cabin crew is a deviation from the required minimum number and requires close monitoring. Changes to evacuation procedures with a reduced number of cabin crew are required to be acceptable to the Competent Authority.
The minimum number of cabin crew required in the passenger compartment may be reduced under conditions stated in ORO.CC.205 incl. AMC1 ORO.CC.205 (c)(1). Procedures must be established in the operations manual; it has to be ensured that an equivalent level of safety is achieved with the reduced number of cabin crew, in particular for evacuation of passengers.

 

View

Was this helpful?

Vote up  2
Vote down  0

Instructor and Examiner being the same person – conflict of interest

Instructor who provided any topic of the Initial training should not act as Examiner to avoid conflict of interest. What about small operators / cabin crew training organisations employing only one ground Instructor, for example to cover dangerous goods or aero-medical aspects and first aid?

Reference: Regulation (EU) No 1178/2011 Aircrew and ED Decision 2012/006/R are available on EASA website.

ED Decision 2012/006/R, AMC1 ARA.CC.200(b)(2) clarifies that in such cases, the operator/training organisation establishes procedures to avoid situations that could lead to a conflict of interest, e.g. where an Instructor has to check/evaluate the proficiency of the trainee he/she has trained.
The qualifications of Instructors/Trainers, as well as of Examiners, are not defined at EU level, and remain to be defined by each Member State. Therefore, only the Competent Authorities may assess, when approving the training and checking programmes of the operator/training organisation, if the procedures can ensure that the objective of the rule is met. 
 
AMC1 ARA.CC.200(b)(2) Approval of organisations to provide cabin crew training or to issue cabin crew attestations 
PERSONNEL CONDUCTING EXAMINATIONS
For any element being examined for the issue of a cabin crew attestation as required in Part CC, the person who delivered the associated training or instruction should not also conduct the examination. However, if the organisation has appropriate procedures in place to avoid conflict of interest regarding the conduct of the examination and/or the results, this restriction need not apply.
View

Was this helpful?

Vote up  6
Vote down  2