Frequently asked questions

Regulation (EU) 1321/2014 lays down in Appendix I to Part 66 the modules that need to be passed in order to access a particular category. Those modules that are common to two categories, may be used to obtain different categories or subcategories, if the module that has been passed in a certain category or subcategory has the same content with a level equal to or higher than in the other categories or subcategories to be obtained.

Point 1 of Appendix III of Annex III (Part-66) to Regulation (EU) 1321/2014 provides that theoretical and practical training must have been initiated and completed in the three years preceding the application for the entry of the type rating, regardless of whether an LMA Part 66 licence is already held or not.

The evaluation for approval of a Maintenance Technician Training Organisation Part 147 has no fee

The appointment must be made in writing by the quality manager of the organisation, which is prior to the start of the OJT. There must also be a signature of “received” by the data subject (evaluator or supervisor) in order to justify that he is aware of his or her role. There is no established format for such appointments.

Applicants who complete basic training at an approved Part 147 organisation and then pass the examinations in another approved Party 147 organisation, will be granted full basic course consideration and, therefore, the reduction of the basic experience requirement will be maximum, eventually remaining within 1 or 2 years. 

The combination of Certificates of Recognition (only complete basic training + examination of modules) will be sufficient for the competent authority to recognise that the basic training course has been successfully ‘completed’. 
 
See also AMC of Appendix III to Part 147 "Certificates of recognition referred to in Annex IV (Part 147) – EASA Format 148

A B1 can perform transponder check tasks, as long as: 

• Use automated testing equipment (which does not require previous calibrations)
• Test results are GO/NO GO 
• Be trained in the use of such equipment.

There is no limitation in the standard or in the EASA guides that prevent a certifier from performing critical tasks in its first year.  
However, the organisation may add additional requirements in its maintenance organisation manual.

Relevant training serves to reduce the basic experience requirement to obtain a Part 66 LMA license.

Relevant training shall be considered:

• Higher-grade vocational training courses in the following specialties:
  • Superior Technician in Aeromechanical Maintenance (for B1).
  • Superior Aviation Maintenance Technician (for B2).
     
• Higher grade training courses in maintenance of the following specialties:
  • Aeromechanical turbine engine aircraft (for B1.1).
  • Aeromechanical of piston-engine aircraft (for B1.2).
  • Aeromechanical turbine engine helicopters (for B1.3).
  • Aeromechanical of piston-engine helicopters (for B1.4).
  • Electronic and avionic systems in aircraft (for B2).
     
• Training corresponding to a basic training course in a subcategory of B1 other than that requested in an organisation Part 147.

However, the consideration of relevant training does not exempt from passing the examinations corresponding to the basic training modules of Part 66 of the category or subcategory of the licence that is intended to be obtained.

A) Preflight inspection vs “preflight” interval maintenance inspection
Some TCH (usually helicopters) include in the maintenance documentation inspections with interval “preflight” or “before the first flight-BFF”. The content of these inspections is usually similar to the content of the pre-flight inspection included in the aircraft flight manual (AFM). The criterion to be applied in order to register its completion is:

In cases where the maintenance documentation (SMM, AMM, etc.) and the flight manual (AFM) include identical tasks, it is considered acceptable for the pilot to carry out inspections under the operation umbrella (signing the pre-flight inspection section) without having to perform a Maintenance “Release”. Normally this will not happen, as there are usually modifications incorporated into the aircraft that include pre-flight inspections linked to the Maintenance Manual.

B) Pilot-certifiers in approved line stations
Here are some criteria on how to deal with pilot-certifiers when certifying tasks in approved line stations (lines included in the MOE):

• There needs to be a Part 66 certifier assigned to the line.
• The availability of the Part 66 certifier to attend the facilities should be clearly identified in the production plan when necessary.
• The pilot-certifier can only certify simple tasks (mainly ALF, BFF, TA) to perform tasks according to 145.A.30 j) 4) since the certifier is not full time in the installation (at the moment the installation would be treated as “not supported”)

The following link to the EASA website  is included as an additional reference.

RESPUESTA DE EASA

The following aspects to be taken in consideration:

• it is possible to release component maintenance on an internal release document (IRD) when this component will be installed on an aircraft by the same maintenance organisation (145.A.50(d));
• The CAMO/operator of the aircraft should be in agreement; and 
• all the information normally required for an EASA Form 1 should be adequately detailed in the IRD (and in MOE procedure). In this case the IRD is considered to be equivalent to an EASA Form 1 for 145.A.42 purpose