Part-145

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, or,

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

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Certification of maintenance

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

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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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?

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, maintenance data has direct influence on many processes of the AMO therefore it should also be available during the initial approval and continuous surveillance audits on the AMO to demonstrate the overall capability of the organisation to perform maintenance.

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

Within the privilege described in 145.A.75(c) a Part-145 maintenance organisation 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 the need for line maintenance in such case should be understood as arising from special occasion, not frequent, regular or recurrent. The repetitive use of this privilege at the same location should not be foreseen.

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 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 etc. In particular, it should describe the maximum duration of such line maintenance activity at that location.

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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.
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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.

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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.

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

Requirement

Reference

The accountable manager shall demonstrate a basic understanding of Part-145.

145.A.30(a) point 3.

The person or group of persons nominated responsible for ensuring that the organisation complies with Part-145 (including the Quality Manager) shall be able to demonstrate

  • relevant knowledge, background and satisfactory experience related to aircraft or components maintenance as applicable,
  • a working knowledge of Part-145,

145.A.30(b) point 3.

 

The organisation shall establish and control the competence of personnel involved in any maintenance, 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

 

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