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.

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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.

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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.

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