Is Part-M applicable to approved Part-145 organisations?
Yes, in addition to the Part-M or Part-ML provisions directly referred to in Part-145 (such as reference to point M.A.304 or ML.A.304 in 145.A.48), certain other requirements laid down in Part-M or Part-ML should also be considered by these organisations. Guidance on this subject is given in ‘GM Article 4(1)’.
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 (Part-145) 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.) or the owner needs supporting maintenance service for a short period at a new location due to a special occasion or particular reason.
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.
How to easily update the “EASA Form 1 – MF/145 Issue 2” to “EASA Form 1 – MF/CAO/145 Issue 3”?
Purpose of the FAQ
This FAQ is intended to recommend the industry and national competent authority (NCA) an easy way to implement the ‘EASA Form 1 Issue 3’, applicable from 24.03.2020, by the Maintenance organisations.
Description of the issue
The Regulation (EU) 2019/1383 updated the Appendix II to Annex I (Part-M) — Authorised Release Certificate — EASA Form 1 by changing the footer of the form in order to add the reference of the Part-CAO.
Some organisations may still have in stock hardcopies of EASA Form 1 Issue 2.
In such case, due to the fact that there is no change in the content of the EASA Form 1 or/and in its completion methodology, for the Part-145 and Part-M, Subpart F approved organisations, the change can be done by:
- crossing out the footer in an ‘EASA Form 1 – MF/145 Issue 2’ and replacing it by ‘EASA Form 1 – MF/CAO/145 Issue 3’; or
- accompanying the Form 1 with a communication explaining that the footer should be read as ‘EASA Form 1 – MF/CAO/145 Issue 3’ in accordance with the MOE/MOM procedure; or
- by other means acceptable to the NCA.