Continuing Airworthiness

 [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).

No, non-complex motor-powered aircraft used by commercial ATO or commercial DTO cannot be maintained by independent certifying staff because in accordance with M.A.201(h) or ML.A.201(e)(2), these aircraft  require maintenance release by an approved maintenance organisation (Part-CAO with maintenance privilege, Part-M Subpart F or Part-145).

Note: ‘GM1 ML.A.201(e)’ provides examples of aircraft not considered to be operated by a commercial ATO or a commercial DTO.

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.

This question arises because of the different understandings of license validity in Commission Regulation (EU) No 1178/2011 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 or ML.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 or Appendix II of Part-ML).

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”. For Part-ML the same information can be found in AMC1 ML.A.803 (ED Decision 2020/002/R).

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:

Note:

As per the definition of ‘maintenance’ in article 2 (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)/ML.A.201(d)].

Regulation (EU) No 1178/2011 was amended in July 2018 to introduce Part-DTO as regards to declared training organisations (ref. Reg. (EU) 2018/1119). Regulation (EU) No 1321/2014 was therefore amended and aligned the Continuing Airworthiness obligations of ATO with those of DTO. 

This means:

Please also refer to GM1 ML.A.201(e) which provides examples of aircraft not considered to be operated by a commercial ATO or a commercial DTO.

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.

Assuming the aircraft satisfies the conditions for extension established in M.A.901 or ML.A.901, 30 days is the maximum allowed period for which the ARC extension can be anticipated without losing the continuity of the airworthiness review pattern. This means that the new expiry date is established as one year after the previous expiry date (AMC M.A.901(c)2, (e)2 and (f), ML.A.901(d)).
 
If the extension is anticipated by more than 30 days, the new expiry date will be established as one year after the date of extension. 

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 100-h/annual inspection contained in the maintenance programme conducted together with the Airworthiness Review of the Part-ML aircraft:
   • by an approved maintenance organisation (145.A.75(f) or CAO.A.095(c)(2)) (see also ML.A.901(b)(3)); or
   • by independent certifying staff holding an ARS authorisation (see ML.A.901(b)(4)) for aircraft operated under Annex VII (Part-NCO) to Regulation (EU) No 965/2012 or, for balloons not operated under Subpart-ADD of Annex II (Part-BOP) to Regulation (EU) 2018/3951 or for sailplane, not operated under Subpart DEC of Annex II (Part-SAO) to Regulation (EU) 2018/1976.

Remark

From regulatory perspective, cases 1 and 2 are explicitly considered by ‘AMC M.A.707(a)’ and ‘AMC1 CAMO.A.310(a)’ [2nd bullet of point (5), respectively point (e)] 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 happens to be also Certifying staff (including independent certifying staff).

Remark:
Iaw M.A.901(l) or ML.A.903(b), 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.

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 or CAO, and
   2. maintained for the previous 12 months by Part-145, Part-M Subpart F or Part-CAO organisations.

AND

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

Thus, the procedure for the extension established in the CAMO or CAO 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.

CA(M)O 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 CA(M)O 1 to CA(M)O 2. As the consequence CA(M)O 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 months. Are the requirements of the M.A.901(b) point 1 satisfied?

The intent of the point M.A.901(b) point 1 is to define the ‘controlled environment’ (see also ML.A.901(c)(1)) by indicating that the aircraft must be managed during last 12 months by unique CA(M)O, which indirectly refers to a standard term of validity of the ARC.  Therefore, if the aircraft has been managed by more than one CA(M)O 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.901(n) or ML.A.903(d) the 90 days anticipation for the ARC issue shall be used to allow the physical review to be performed during a maintenance check. Hence the intention of the rule is not to address the transfer of the aircraft within those 90 days with the purpose of avoiding the forthcoming airworthiness review.

Concerning the ARC extension and its 30 days anticipation, point M.A.901(f) [AMC M.A.901(c)2, (e)2 and (f)] or ML.A.901(d) are intended for 2 consecutive extensions by the same CA(M)O managing the continuing airworthiness of the aircraft from the date of issue of the ARC. Therefore, an ARC extended for the first time by an organisation cannot be extended a 2nd time by another organisation, because this constitutes a ‘breach’ in controlled environment.

For the import of an aircraft in the EU under Part-M regime, the provisions of M.A.904 require the accomplishment of an airworthiness review in accordance with point M.A.901.

Note: AMC M.A.904(a)(2) defines specific elements to be considered for imported aircraft.

However, when performing the airworthiness review of an imported aircraft in accordance with point M.A.901 and its AMC, it may happen that ‘AMC M.A.901(k)’ is not fully satisfied in which certain components subject to the review may not hold an EASA Form 1 (or equivalent under a bilateral agreement) In such a case, other component releases to service or serviceable tags may be acceptable for the competent authority of the importing Member State.

Nevertheless, it is important to ensure that the information required by M.A.305(c) and (d) related to the status of ADs, life accumulated by life-limited parts and time-controlled components, modifications and repairs is available.

The term “back to birth” is not used in European regulations. The requirements that apply to a life-limited part or a service life-limited component (see definition in ML.A.503(a)) are basically stated in M.A.305 (d)&(e) or ML.A.305(e). 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 life-limited part or 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 or ML.A.305, e.g. an airworthiness directive, or any other information that could be affecting the configuration of the aircraft, must be retained too.

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, 145.A.55(c) or CAO.A.90(a) are required to be kept by an AMO (respectively Part-M/F organisation, Part-145 organisation or CAO with maintenance privileges). 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(e)(2) or ML.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 or CAO with Continuing airworthiness management privileges when required by M.A.201 or ML.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/CA(M)O 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/CA(M)O can demonstrate compliance with M.A.305 or ML.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/CA(M)O. 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 and CAO with Continuing airworthiness management privileges. The AMO shall retain the records for 3 years, whereas the CAMO and CAO with Continuing airworthiness management privileges 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/CAO with Continuing airworthiness management privileges.

*: Transmitted records is a subset of AMO maintenance records provided to the CA(M)O. Certain transmitted records do not need to be kept as a record by the CA(M)O 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
_______________________________________________________________________________________________________

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

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(e) or ML.A.305(h) for determining the continuing airworthiness and configuration of the aircraft.

For aircraft complying with Part-ML (refer to Article 3(2) of Regulation (EU) No 1321/2014, the AMP should be based either on the applicable ICA or on the Minimum Inspection Programme (MIP) defined in ML.A.302(d).

The owner, when she/he has not contracted the continuing airworthiness management to  a CAMO or CAO [see ML.A.201(f)], should ‘declare’ the AMP assuming responsibility for its content. Such declared AMP does not need to be sent to the competent authority. Except for the mandatory requirements (see also remark below) the owner may decide, under his/her full responsibility, to deviate from the applicable scheduled maintenance recommendations (including ICA if the AMP is not based on the MIP) without the need to justify such deviation(s) (see GM1 ML.A.302).

If the aircraft is managed by a CAMO or CAO, such organisation should ‘approve’ the AMP. Deviations from the applicable scheduled maintenance recommendations (including ICA if the AMP is not based on the MIP) should be justified and properly recorded.

In both scenarios though (AMP declared by owner or approved by CAMO/CAO), when the AMP is not based on the MIP, the deviations to the applicable ICA shall not result in a less restrictive task than the corresponding MIP task. 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 ‘GM1 ML.A.201’, ‘GM2 ML.A.302’.

In addition, the AMP shall be reviewed annually. For declared AMP, this review should be done by the person who performs the airworthiness review during its accomplishment (see AMC1 ML.A.302(c)(9)). For approved AMP, the review can be done either by the Airworthiness Review Staff (ARS) during the airworthiness review or by the CAMO itself.

If during the airworthiness review it is observed that there are discrepancies on the aircraft linked to deficiencies in the content of the aircraft maintenance programme, the AMP must be amended. The competent authority shall be informed in the case where the ARS does not agree with the measures taken to amend the AMP. 

Remarks:

In accordance with ML.A.302 and in particular ML.A.302(c)(4), 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).

References:

Please refer also to ‘AMC2 ML.A.302’ (EASA Form AMP), ‘GM1 ML.A.302’ and ‘AMC1 ML.A.302(d)’ (content of MIP).

In a normal scenario :

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

However, there may be different considerations that render the normal scenario no longer applicable. For example:

Case 1: The interval of the maintenance task has been previously subject to a one-time extension using an approved procedure included in the aircraft maintenance programme (refer to Appendix I to AMC M.A.302 point 4) normally called ‘permitted variation’ or ’tolerance’. In this case the next due date should be calculated using the previous due date (as opposed to accomplishment date) or as agreed by the competent authority.

For aircraft regulated by Part-ML the situation is different when applying the tolerance of 1 month  foreseen in ML.A.302(d), the next interval shall be calculated from the accomplishment date (refer to ML.A.302(d)(1) and AMC1 ML.A.302(d)).

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 on aircraft.

Case 3: The task is released as part of a maintenance check/visit, where the duration of the check/visit is significant compared to the interval of the task. In this case, there may be significant difference between date of accomplishment and date of release. For example, a check/visit that lasts for 2 months and an inspection that has an interval of 3 months. In this case, either the task is carried out on the last days of the maintenance check/visit and the next due date is calculated from the CRS, or the task is carried out at the beginning of the visit and the next due date should be calculated from the date of accomplishment.

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

Part-M:

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

This means that the owner/operator/CA(M)O 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(h), 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 annually.

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 CA(M)O, the CA(M)E (Continuing Airworthiness Management Exposition/Combined Airworthiness Exposition) should describe the AMP revision policy (including ‘periodic review’) under point 1.2 [Appendix V to AMC M.A.704], point 1.2 [AMC1 CAMO.A.300]  or point D.3 [AMC1 CAO.A.025].

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.

Part-ML:

ML.A.302(c)(9) requires an annual review of the AMP.
For aircraft regulated by Part-ML the review of the AMP may be carried out with the airworthiness review (AR) of the aircraft by the person who performs such AR.

Such a review allows to determine if an AMP revision is necessary to still comply with the obligations of ML.A.302(c) or ML.A.302(d) and ensure that the AMP or MIP continues to be valid in light of the operating experience. As a minimum, ML.A.302(c)(9) states it should be at least annually.

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.)

However, in accordance with ML.A.302(c)(9), 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 CA(M)O, the CA(M)E (Continuing Airworthiness Management Exposition/Combined Airworthiness Exposition) should describe the AMP revision policy (including ‘periodic review’) under point 1.2 [Appendix V to AMC M.A.704], point 1.2 [AMC1 CAMO.A.300]  or point D.3 [AMC1 CAO.A.025].

Remark:

AMP regulated by Part-ML are declared by the owner or approved by the CAMO or CAO (ML.A.302(b)).

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)(2), 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 has 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 for which the Basic Regulation is not applicable, has to comply solely with the national rules of the state of registry; and
• 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.

Part-M

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(h) – see FAQ n.47406].

b) It should form part of the analysis of the effectiveness of the AMP (if required by M.A.301(e)),

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 a formal reliability programme if required by M.A.302(g) 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 CA(M)O involved, those points also have to be emphasised within the CA(M)E, as specified in Appendix V to AMC1 M.A.704, AMC1 CAMO.A.300 or AMC1 CAO.A.025.

Two different cases:

The escalation of AMP task intervals falls into the alternative instructions proposed by the owner/CA(M)O [M.A.302(e)] 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(b)(6)] 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(e).

Regarding case 2:

An indirect approval of the AMP through a CA(M)O 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(g) 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 point (4)].

Part-ML

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 [[ML.A.302(c)(9) – see FAQ n.47406].

b) The effectives of the AMP should be assessed at least by an annual review [ML.A.302(c)(9)]. 

c) The AMP may include additional maintenance actions [ML.A.302(c)(3)] supported by collection and analysis of in-service experience.

‘GM1 ML.A.302(c)(3)’ provides detailed guidelines for the integration of this information into the AMP.

d) If there is a CA(M)O involved, those points also have to be emphasised within the CA(M)E, as specified in Appendix V to AMC M.A.704, AMC1 CAMO.A.300 or AMC1 CAO.A.025.

Two different cases:

The escalation of AMP task intervals falls into the alternative instructions proposed by the owner/CA(M)O [GM1 ML.A.302(c)(2)(b)] 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), tasks related to emergency equipment, critical components…

Case 2:

Escalation of non-safety-related task (e.g. task recommended by a Service Letter) intervals

Escalation approval:

The approval of the escalation is carried out by the CAMO or CAO [ML.A.302(b)(2)]. For declared AMP no approval is needed [ML.A.302(b)(1)].

Remarks:

• In all cases, task de-escalation may need to be considered based on the supporting data.
• Escalation should not be confused with ‘permitted variations’ to AMP intervals, which applies to a unique aircraft for a unique occasion [GM1 ML.A.302(c)(3)].

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(g).

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.

For Part-ML aircraft, the principles of the AMP development are described in FAQ n.43423.

Part-M Subpart G, Part-CAMO and Part-CAO do not contain specific requirements for the identification of deputies to “nominated persons” as it is foreseen in Part-145 (145.A.30(b)(4)).

Nevertheless, the CAMO or CAO needs to take into account the conditions for the continued validity of the approval laid down in M.A.715, CAMO.A.135 or CAO.A.110, in particular in case of findings or in case of changes.

The CAMO or CAO should ensure that they remain in compliance even during short/medium absence of the nominated persons, this could be achieved by identifying in the CAME or CAE “one or several deputies” and the conditions under which the deputies will assume such responsibility. For longer absence of the nominated person, it is recommended to identify a new nominated person. For Part-M Subpart G organisations, the nomination and acceptance by the competent authority is done using the EASA Form 4. For Part-CAMO and Part-CAO approvals no EASA Form 4 is foreseen and the acceptance by the competent authority is formalised by the approval of an amendment to the exposition.

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) or CAE (Combined Airworthiness 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 organisation is responsible to issue the indirect approval;
• how the amendments are controlled; and
• how and when the competent authority is informed of an AMP amendment.

Based on M.A.302(c), the indirect approval may only be used when:

• the aircraft is managed by a CAMO/CAO or there is a limited contract between the owner and the CAMO/CAO for the development and approval of the AMP;
•    and
• the aircraft managed by the CAMO/CAO is registered in the Member State ensuring the oversight of this CAMO/CAO (unless an agreement exists between the competent authority for the AMP and the competent authority of the CAMO/CAO).

Remark

AMPs regulated by Part-ML are not subject to an approval by the competent authority.

Yes, the compliance monitoring/quality system is part of the activities of the CAMO or CAO and therefore it should be monitored by internal audit.

Points M.A.712(b), CAMO.A.200(a)(6) or CAO.A.100(b) requires that the compliance monitoring/quality system monitors the compliance of the organisation with its relevant requirements and procedures.

The compliance monitoring/quality procedures are considered to be within the scope of this monitoring function. Therefore, the compliance monitoring/quality system should also be subject to audits and the CAMO or CAO audit programme/plan needs to reflect this.

Besides that, the audits conducted in respect of the compliance monitoring/quality system should satisfy the requirement of independence. This means that audits should be carried out by personnel not responsible for the functions, procedures or products being checked.

So, the compliance monitoring/quality staff cannot audit the compliance monitoring/ quality system themselves because of the necessary independence of the audit. Therefore, to audit the compliance monitoring/quality system, it is acceptable:

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

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

For a small CAO, as defined in CAO.A.100(e), the quality system may be replaced by regular organisational review. Further information on the organisational review can be found in ‘AMC1 CAO.A.100(f)’ and ‘Appendix II to AMC1 CAO.A.100(f)’.

The CAMO has the obligation, for complex motor-powered aircraft and aircraft used by air carriers licensed in accordance with Regulation (EC) No 1008/2008, to establish a procedure to assess non mandatory modifications and inspections (e.g. Service Bulletins).

This assessment should result in a decision to implement or not the recommendation provided in such non-mandatory information (e.g. perform the inspection, embody the modification, amend the aircraft maintenance programme (AMP)).

This assessment procedure should take into consideration several aspects, as the case may be, including but not limited to:

• the applicability to the operator’s fleet (e.g. type of operating environment, utilization, aircraft configuration);
• achievement of operator’s safety objectives;
• mitigating potential aviation safety risks already identified by the operator;
• mitigating potential aviation safety risks not yet apparent to the operator but identified by other operators or TC/STC holder, for aircraft in a similar operational environment;
• reliability improvement of the aircraft and components; and
• improvement of the effectiveness of the AMP.

In case of potential aviation safety risks, the CAMO should review the hazard(s) identified in the recommendation and the proposed maintenance action and its timeframe (i.e. timeline to embody the modification or amend the AMP). This is the main purpose of the expression “making use of the organisation’s safety risk management process”. If necessary, the CAMO will perform a safety risk assessment (e.g. in terms of probability and severity of consequences) and a review of the related mitigations.

Typically, SBs are issued for technical purposes (as mitigation or safety risk control). For instance, a SB could provide the following:

• an elimination of an identified hazard by the embodiment of a modification, or
• reducing the safety risk (i.e. the severity and/or likelihood) of the consequences of an identified hazard by the embodiment of a modification, or
• reducing the likelihood of the consequences of an identified hazard by performing repetitive inspections.

Since SBs are also used for other purposes (e.g. optional equipment installation, commercial retrofit) and not only for potential safety-related situations, it is not required to use safety risk management process for each SB.

The CAMO should use its safety risk management process to determine if the hazard identified in the SB applies to the managed fleet and what the associated risk is, and/or whether the proposed action (modification/inspection) are applicable, effective and reasonable. For clarity, it is not intended that the CAMO should redo the safety assessment performed by the design approval holder; the CAMO assessment should be tailored to its fleet and related operations.

The referred CAME procedure for the assessment of non-mandatory modifications and inspections should ideally describe the decision-making process and mandate to record the decision taken and its justifications (e.g. based on considerations of costs vs benefits such as safety or reliability).

The decision to embody a modification may require the change management process to be followed to ensure proper coordination between the aircraft operator, the CAMO and the approved maintenance organisation. For example, a modification that affects Mass and Balance, requires maintenance check flights, introduces revised flight manual procedures, maintenance manual procedures, changes to the AMP, which needs to be managed to ensure proper dissemination of the information, training, review of existing hazards, and review of risk assessment, as applicable.
 

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)’.

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.

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.

Please check for the answer published here.

The current point 2.6 of AMC2 145.A.50(d) or AMC1 CAO.A.070(a) refers to the issue of an EASA Form 1 for serviceable aircraft components removed from serviceable aircraft registered in a Member State (*).

This AMC provision is to be used only for components removed from serviceable Member State registered aircraft, not from engine/component off-aircraft, regardless of whether such engine/component is serviceable or not. Components removed from a higher assembly (engine or another component) off-aircraft are expected to undergo workshop maintenance in accordance with the relevant maintenance data before the EASA Form 1 (certifying such maintenance) is issued.

Note that an A-rated Part-145 maintenance organisation or a Part-CAO organisation with class “aircraft’’ can issue an EASA Form 1 following a “removed serviceable” procedure for a (sub)component removed from a higher assembly component when such higher assembly is still installed on (or temporarily removed from) serviceable Member State registered aircraft, following the procedure of the referred AMCs.

(*) means an aircraft which is registered in a Member State and holds a valid (R)CofA issued in accordance with Reg. (EU) No 748/2012 and an ARC.

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) or CAO.A.100 (b) (1) 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 or Part-CAO 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. For Part-CAO this subject is explained in AMC1 CAO.A.100(b).

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 or CAE and approved by the competent authority.

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.

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

A certificate of release to service can be issued by a person from the subcontractor who has received a certification authorisation from the Part-145 organisation in accordance with the certification authorisation procedure of the MOE including the assessment of competence.

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

For maintenance by Part-CAO the situation is different. Only ‘specialised services’ (e.g. NDT) can be subcontracted to another organisation, in accordance with the appropriate procedure set out in the CAE and approved by the competent authority (CAO.A.095(a)(2)). In accordance with AMC1 CAO.A.025 the procedure should be part of chapter B.7 ‘Subcontracting’.

A certificate of release to service can be issued by a person from the other organisation who has received a certification authorisation from the CAO in accordance with the certification authorisation procedure of the CAE.

The certificate of release to service will always be issued under the CAO approval reference.

This answer is separated in two tables. One table is for organisation holding a Part-145 approval and the second table is for organisations holding a Part-CAO approval.

Part-145:

Note: In case of non-EU organisations approved by the EASA in accordance with Part-145, the Part-66 licence could be read as “Part-66 or national licence in accordance with Part-145 Appendix IV”

Part-CAO:

Note: In case of non-EU organisations approved by the EASA in accordance with Part-145, the Part-66 licence could be read as “Part-66 or national licence in accordance with Part-145 Appendix IV”

Maintenance data has direct influence on many processes of the approved maintenance organisation (AMO) and contributes to demonstrate the overall capability of the organisation to perform maintenance.

The maintenance data either can be arranged directly by the AMO or provided by the customer/operator as specified by 145.A.45(a), M.A.609 or CAO.A.055(a). 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.

Additionally, as part of the obligation for maintenance records, used maintenance data shall be:

• recorded (in compliance with 145.A.55(c), M.A.614(c) or CAO.A.090(b)) 
• 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), AMC M.A.614(c)]; and
• accessible for auditing purpose

to demonstrate that the organisation worked in compliance with their respective requirements.

Normally the flight crew should not release CMR task unless that task is included in a “repetitive pre-flight airworthiness directive” under the conditions of 145.A.30(j)(3), M.A.606(h)(1) or CAO.A.040(c)(1)

In case of aircraft operated away from a supported location, the provisions of 145.A.30(j)(4), M.A.606(h)(2) or CAO.A.040(c)(2) could be used for CMRs as long as all the applicable conditions are met. In particular:

• sufficient practical training has been carried out.
• there is a procedure in the Maintenance Organisation Exposition, Maintenance Organisation Manual or Combined Airworthiness Exposition (CAE).

the task is considered “minor maintenance or a simple check” (AMC 145.A.30(j)(4) point 2(i) or AMC M.A.606(h)(2) point 2).

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.

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

See points 66.A.3 and 66.A.20 of Annex III (Part-66) to Regulation (EU) No 1321/2014 can be found on the Agency website https://www.easa.europa.eu/regulations#regulations-continuing-airworthi… or in the eRules https://www.easa.europa.eu/document-library/easy-access-rules/easy-acce…)

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 an aircraft type rating TR endorsed in the AML, an applicant needs:
   
   1. Type Training (Theoretical and Practical) (66.A.45)
   2. On-the-job Training (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 AML 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 the European system.

Click on the pictures to zoom in.

The initial application for a Part-66 aircraft maintenance licence shall be made to the competent authority of one of the Member States (MS). Please contact this competent authority for an application Form (EASA Form 19) and specific details concerning the application.

The EASA Form 19 shall be submitted to the MS together with evidence of compliance with the requirements. MS will specify the related fees and how compliance with the requirements shall be demonstrated.

See 66.A.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 (AML) shall be made to the competent authority of the MS who issued the licence. Please contact this competent authority for an application Form (EASA Form 19) and specific details concerning the application.

The EASA Form 19 shall be submitted to the MS together with evidence of compliance with the requirements. MS will specify the related fees and how compliance with the requirements shall be demonstrated.

See 66.A.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.

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: https://www.easa.europa.eu/the-agency/member-states .

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.

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.

Anybody able to pass the basic knowledge examinations and fulfil the basic experience requirements can get the related 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 propose amendments to the regulations to account for cases of people with special needs during examinations: a single regulation cannot cover all individual cases. If a Member State intends to introduce any such adaptation, Regulation EU 2018/1139 (the BR) includes the possibility for the Member States to grant an exemption under the Article 71(2), after evaluation of the individual conditions for the case.

As an additional information, the Agency already issued several positive recommendations for such exemptions (e.g. for candidates with confirmed dyslexia, i.e. 25% additional time). Please contact your competent authority for details.

For further information about the flexibility provisions under the BR, please see 'Safeguard & Flexibility Provisions'.

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.

Please note that none of the bilateral agreements between the EU and third countries (at present US, Canada, Brazil and China and Japan) have the maintenance licences in their scope.

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

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.

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.

It is not mandatory to gain maintenance experience in a Part-145 organisation. According to the AMC 66.A.30(a) point 4, aircraft maintenance experience gained within different types of maintenance organisations (under Part-145, M.A. Subpart F, Part-CAO, 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 (see AMC 66.A.30(e)). 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.

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.

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).

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 66.A.10, 66.A.25, 66.A.30 and related AMC/GM.

According to 66.B.100(b), the competent authority shall verify that all required modules of Appendix I or Appendix VII 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, to 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.

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 national competent authority on those aircraft that do not require a type training (typically Group 2, Group 3 and Group 4 aircraft according to Appendix I to the AMCs to Part-66). So, it is true that the examiners authorised by the national 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”.

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, B2 and L5 licences, in case where the aircraft type is the first in a licence category or subcategory, an OJT training has been performed (derogation for Group 2 and 3 aircraft see 66.A.45(d)).

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’).

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.

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).

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 comply 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 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.

In the case of type training for airships in Group 1, the courses shall be directly approved by the competent authority in all cases. The competent authority shall have a procedure to ensure that the syllabus of the airship-type training covers all the elements contained in the maintenance data from the Design Approval Holder (DAH) (66.B.130(b)).

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).

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, it 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 three-year timeframe from the date you started the TRT course [see Part-66 Appendix III 1.(a)(iv) and (b)(v)].

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:

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.

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.

Note: See AMC to Section 6 of Appendix III to Part-66 point 4 and 5

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 …, to a B2 or L5,
• and be adapted to the privilege of each licence category / subcategory as defined in 66.A.20(a):
  • for a B1 licence: aircraft structure, power plant and mechanical and electrical systems + work on avionics system with simple test but not including trouble shooting;
  • and those related to a B2: avionics, aircraft electrical system tasks and avionics/electrical tasks within mechanical and power plant systems; or
  • and those related to a L5: aircraft structure, power plant, mechanical and electrical systems, radio, Emergency Locator Transmitters (ELT), transponder systems and other avionics systems requiring simple tests to prove their serviceability.

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.

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.

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 point (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.

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 with A rating or 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, 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 a 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.

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, Part-ML, Part-145 and/or Part-CAO 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)(2)  and GM 66.A.20(b)2  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”.

The competent authority of the Member State issuing the licence may include in the Annex (Section XIV) of EASA Form 26 types for which the Basic Regulation is not applicable. The privileges endorsed for these types are based only on the national rules. The use of Section XIV of EASA Form 26 is optional.

EASA does not have any information about these types. If you want to get information about them, please contact the competent authority.

The “validity” of the Part-66 licence is not affected by point 66.A.20(b)(2). The licence itself remains valid 5 years from the last renewal.  
Nevertheless, compliance with point 66.A.20(b)(2) is required to ensure that the maintenance privileges are exercised by certifying staff that hold sufficient recent experience.
If you do not meet this point anymore, you lose your rights to exercise your privileges of certifying staff or support staff. 
Therefore, as holder of an aircraft maintenance licence, to exercise your certification privilege in accordance with 66.A.20(b)(2), please ensure:

•  You have accumulated 6 months of experience in the previous 2 years;

Note: see also AMC 66.A.20(b)(2) for possible reductions of experience, in particular for independent certifying staff. Demonstration of experience should be made on the particular or similar aircraft. Guidance on ‘similar’ aircraft is also provided in AMC 66.A.20(b)(2).

or

•  You can demonstrate that in the last 2 years, you have met the provisions for the issue of appropriate privileges, which means (refer to 66.A.45), as applicable to the case:

1)    going to a type-training course again (the need for OJT has to be assessed on case-by-case basis);

or

2)    when the aircraft endorsement does not require type training (aircraft belonging in Group 2, 3 or 4):

       a) pass a type evaluation, including practical assessment; 
or
        b) when no type evaluation is required for aircraft endorsement, for example:
            - a B2/B2L license endorsed with a full group 3 or 4 rating; or
            - for L-category licences (other than L5), 
being able to demonstrate, in the last 2 years, practical experience, which shall include a representative cross section of maintenance activities relevant to the licence subcategory (B2/B2L, L1, L1C, L2, etc.)

Note: “A representative cross section of maintenance activities” means representative cross-section of the tasks listed in Appendix II to AMC to Annex III (Part-66) “Aircraft Type Practical Experience and On-the-Job Training - List of Tasks”. “Demonstrate” means having a record thereof, such as a logbook.
Note: GM 66.A.20(b)2 will be reviewed and amended according to this interpretation  through rulemaking task RMT.0735.
 

The list of typical tasks to be carried out by a category A certifying staff at the line shown in the AMC include a (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.30(g).

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.

There are several scenarios possible depending on the particular case. Here are some most probable cases for category A, B1, B2, B2L, B3 or L:

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 1 or 2 years of maintenance experience (66.A.30).

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 2 or 3 years of experience (if recognised as skilled worker) or 1, 2, 3 or 5 years (66.A.30).

• 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 or Appendix VII 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 1 or 2 years needed, see case No 1) 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 – 2 or 3 years). Standard 1, 2, 3 or 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.

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.

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, the certificate shall state only “Basic training course” and the modules conducted be mentioned on the certificate including the date(s) of the training module(s).

Reference: 147.A.145

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.

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-M Subpart F, Part-145 or Part-CAO 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-M Subpart F, Part-145 or Part-CAO 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.

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.

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), 3.2 and 4.2 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.

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.

“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.

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.

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 a 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.

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, Part-ML, Part-145 or Part-CAO requires the staff to be trained, the appropriateness of such training being delivered would be assessed during the audits of these particular organisations.

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.

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 inspections.