Can a certification maintenance requirement (CMR) be performed by the Flight Crew before flight?
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).
What is the meaning of the Protected Rights in the Appendix IV to Part-145?
The protected rights mentioned in paragraph 2(a) of the Appendix IV to Part-145 were included in the Regulation 2042/2003 for the persons who were already working in a Part-145 organisation in a location situated outside the EU before the entry into force of Part-66. These protected rights allowed those persons to continue exercising (inside that particular Part-145 organisation) the privileges of the certification authorisation issued by that Part-145 organisation without the need to comply with paragraphs 1(c) to 1(f).
If this person changed the employment to a different Part-145 approved organisation after the entry into force of Part-66 (i.e. 28 November 2003), the previous certification authorisation is not valid and he/she needs to receive a new one from the new Part-145 approved organisation. In this case paragraph 2 of Appendix IV is not applicable anymore.
This implies that any new or extended authorisation granted by AMOs to their C/S after the entry into force of Part-66 must comply with paragraphs 1(c) to 1(f) in particular regarding the type training certificates.
What are the training requirements for personnel within a Part-145 organisation, other than those contained in Part-66?
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Requirement |
Reference |
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The accountable manager shall demonstrate a basic understanding of Part-145. |
145.A.30(a) point 3. |
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The person or group of persons nominated responsible for ensuring that the organisation complies with Part-145 (including the Quality Manager) shall be able to demonstrate
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145.A.30(b) point 3.
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The organisation shall establish and control the competence of personnel involved in any maintenance, airworthiness review management and/or quality audits in accordance with a procedure and to a standard agreed by the competent authority. In addition to the necessary expertise related to the job function, competence must include an understanding of the application of human factors and human performance issues appropriate to that person's function in the organisation. This should include also:
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145.A.30(e) and associated AMC/GM. Appendix IV to AMC 145.A.30(e) and 145.B.10(3). AMC 20-22. |
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The organisation shall ensure that personnel who carry out and/or control a continued airworthiness non-destructive test of aircraft structures and/or components are appropriately qualified for the particular non-destructive test in accordance with the European or equivalent Standard recognised by the Agency. Personnel who carry out any other specialised task shall be appropriately qualified in accordance with officially recognised Standards. By derogation to this paragraph those personnel specified in paragraphs (g) and (h)(1) and (h)(2), qualified in category B1, B3 or L in accordance with Annex III (Part-66) may carry out and/or control colour contrast dye penetrant tests. |
145.A.30(f) and AMC 145.A.30(f). |
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By derogation to paragraphs (g) and (h), in relation to the obligation to comply with Annex III (Part-66), the organisation may use certifying staff qualified in accordance with the following provisions: 1. For organisation facilities located outside the Community territory certifying staff may be qualified in accordance with the national aviation regulations of the State in which the organisation facility is registered subject to the conditions specified in Appendix IV to this Part. 2. For line maintenance carried out at a line station of an organisation which is located outside the Community territory, the certifying staff may be qualified in accordance with the national aviation regulations of the State in which the line station is based, subject to the conditions specified in Appendix IV to this Part. 3. For a repetitive pre-flight airworthiness directive which specifically states that the flight crew may carry out such airworthiness directive, the organisation may issue a limited certification authorisation to the aircraft commander and/or the flight engineer on the basis of the flight crew licence held. However, the organisation shall ensure that sufficient practical training has been carried out to ensure that such aircraft commander or flight engineer can accomplish the airworthiness directive to the required standard. 4. In the case of aircraft operating away from a supported location the organisation may issue a limited certification authorisation to the commander and/or the flight engineer on the basis of the flight crew licence held subject to being satisfied that sufficient practical training has been carried out to ensure that the commander or flight engineer can accomplish the specified task to the required standard. The provisions of this paragraph shall be detailed in an exposition procedure. 5. In the following unforeseen cases, where an aircraft is grounded at a location other than the main base where no appropriate certifying staff are available, the organisation contracted to provide maintenance support may issue a one-off certification authorisation: (i) to one of its employees holding equivalent type authorisations on aircraft of similar technology, construction and systems; or (ii) to any person with not less than five years maintenance experience and holding a valid ICAO aircraft maintenance licence rated for the aircraft type requiring certification provided there is no organisation appropriately approved under this Part at that location and the contracted organisation obtains and holds on file evidence of the experience and the licence of that person. All such cases as specified in this point shall be reported to the competent authority within seven days of the issuance of such certification authorisation. The organisation issuing the one-off authorisation shall ensure that any such maintenance that could affect flight safety is re-checked by an appropriately approved organisation.
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145.A.30(j) and associated AMC/GM.
Appendix IV to Part-145. |
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In addition to the appropriate requirements of 145.A.30(g) and (h), the organisation shall ensure that certifying staff and support staff have an adequate understanding of the relevant aircraft and/or components, or both, to be maintained and of the associated organisation procedures. In the case of certifying staff, this shall be accomplished before the issue or reissue of the certification authorisation. |
145.A.35(a) and AMC 145.A.35(a). |
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The organisation shall ensure that all certifying staff and support staff are involved in at least six months of actual relevant aircraft or component maintenance experience in any consecutive two-year period. |
145.A.35(c) and AMC 145.A.35(c). |
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The organisation shall ensure that all certifying staff and support staff receive sufficient continuation training in each two-year period to ensure that such staff have up-to-date knowledge of relevant technology, organisation procedures and human factor issues. |
145.A.35(d) and AMC 145.A.35(d). |
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The organisation shall establish a programme for continuation training for certifying staff and support staff, including a procedure to ensure compliance with the relevant paragraphs of 145.A.35 as the basis for issuing certification authorisations under this Part to certifying staff, and a procedure to ensure compliance with Annex III (Part 66). |
145.A.35(e) and AMC 145.A.35(e). |
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Except where any of the unforeseen cases of 145.A.30(j)(5) apply, the organisation shall assess all prospective certifying staff for their competence, qualification and capability to carry out their intended certifying duties in accordance with a procedure as specified in the exposition prior to the issue or reissue of a certification authorisation under this Part. |
145.A.35(f) and AMC 145.A.35(f). |
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The holder of a category A aircraft maintenance licence may only exercise certification privileges on a specific aircraft type following the satisfactory completion of the relevant category A aircraft task training carried out by an organisation appropriately approved in accordance with Annex II (Part-145) or Annex IV (Part-147). This training shall include practical hands on training and theoretical training as appropriate for each task authorised. Satisfactory completion of training shall be demonstrated by an examination or by workplace assessment carried out by the organisation. |
145.A.35(n) and AMC 145.A.35(n). |
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The holder of a category B2 aircraft maintenance licence may only exercise the certification privileges described in point 66.A.20(a)(3)(ii) of Annex III (Part-66) following the satisfactory completion of (i) the relevant category A aircraft task training and (ii) six months of documented practical experience covering the scope of the authorisation that will be issued. The task training shall include practical hands on training and theoretical training as appropriate for each task authorised. Satisfactory completion of training shall be demonstrated by an examination or by workplace assessment. Task training and examination/assessment shall be carried out by the maintenance organisation issuing the certifying staff authorisation. The practical experience shall be also obtained within such maintenance organisation. |
145.A.35(o) and AMC 145.A.35(o). |
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Pre-flight inspections (when the 145 organisation has an agreement with an operator) It should be demonstrated that the personnel carrying out pre-flight inspections have received appropriate training for the relevant pre-flight inspection tasks based on the operator’s CAME. |
ML.A.301(a) |