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.
- 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).
- 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.
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 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.
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.
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.
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 77(1) of Regulation (EU) 2018/1139 (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.
- The airworthiness (initial and continuing) of the aircraft referred to in Annex I 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.
How is it possible to escalate AMP task intervals?
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)].
- 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:
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…
Escalation of non-safety-related task (e.g. non-safety related MRBR task or a task recommended by a Service Letter) intervals
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)
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.
- 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)].
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.