Frequently asked questions

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

A summary table on the applicability of the payment of fees is included:

This applies both to remote audits carried out by the competent authority and to remote audits carried out by approved organisations to their own suppliers and subcontractors. 
Authorities/organisations that decide to use remote audits should describe the functioning of remote audits in their procedures and should consider at least the following points:

• The use of an information technology methodology flexible enough to optimise the conventional audit process. 
• The definition and implementation of controls to avoid abuses that could compromise the integrity of the audit process. 
• Measures to ensure that security and confidentiality are maintained during audit activities (data protection and intellectual property of organisations must also be safeguarded). 

In addition, there must be an agreement between the auditor and the auditee that includes: 

• The platform to be used (e.g.: WebEx, Teams, Lync, etc.); 
• Pre-audit platform compatibility testing; 
• Consider the use of cameras when a physical evaluation is required; 
• Establish an audit plan that identifies the IT means to be used and the use to be made of them in order to optimise and, at the same time, maintain the integrity of the process; 
• If necessary, consider time differences in order to be able to coordinate at reasonable times for both parties; 
• A written statement that the auditee will cooperate to the fullest extent possible and provide the truthful information requested, including the cooperation of subcontracted companies if necessary; 
• Data protection aspects. 

Further information can be found at https://www.easa.europa.eu/faq/116561
Information is also provided in GM1 145.A.200(a)(6) on the use of information and communication technologies for remote audits.

If an organization wants to carry out maintenance on temporary fire bases and it is not a case of AOG or occasional maintenance, that is, if you want to make use of fixed facilities (warehouse, office, etc.) and it is estimated that the use will be greater than 40 days, you must request the opening of a line station for each location.  
Otherwise, support could be provided by a mechanic on board / traveling in a van if the need to request opening of installation (although defining in the EOM the necessary procedures).

EASA ANSWER:

Line stations staffed with one person (the certifying staff) contracted externally may require attention, in particular ensuring:

• this arrangement is sufficient for the work to be performed, the relevant number of aircraft and associated transit schedule. This should take also into account:
  • all maintenance carried out on non-EU aircraft and on behalf of other maintenance organisations (where applicable) [point 2 of AMC 1 145.A.30 (d)].
  • the planned absences (e.g. training, vacation) [point 2 of AMC 1 145.A.30(d)].
  • human performance limitations (145.A.47(b)).
• the arrangement is durable and provides organisational stability [in the spirit of point 1 of AMC 1 145.A.30 (d)].
• the certifying staff is appropriately licenced for the work to be performed. If he/she is only B1 licensed, the organisation should have a procedure on how to deal with work requiring B2 certifying staff [see 145.A.30 (g) and points (3) and (4) of AMC 145.A.30 (g)].
• Contracted staff has a good knowledge and understanding of the Part-145 MOE procedures"

Yes, provided that it has continued to apply the requirements of point 2.8 of AMC 2 of 145.A.50(d) to re-incorporate the component into the EASA system. 
It is not required to ask for more documentation than the Form 1 to the CAMO that orders its installation. In case of doubts about this component, it would be necessary to go to the P145 in question if we are the competent authority (or notify the corresponding authority) to assess whether they have done everything necessary to put the component in the system. But without penalizing CAMO during this process, that is, independently.  
If during this investigation in P145 it is discovered that there have indeed been irregularities with the component, the CAMO will have to be notified and the component will have to be dismantled.

The EOM Evaluation Guide indicates, in the functions of the Compliance Control Officer in section 1.4.2, "7". It is responsible for the preparation of standard practices and procedures (including the EOM and associated procedures) for use within the organization, and ensures their adequacy with respect to Part 145. Could the Maintenance Manager perform this function and then the Compliance Control Manager give the go-ahead?

They are valid. The only difference is that the certificate of recognition on which they appear corresponds to the EASA 148 format, while the basic examinations approved as of 12 June 2024 will appear in an EASA 148a format if they have been carried out in a Part 147 organisation, or in an EASA 148b format (if they have been carried out with the Authority).

How can you perform an OJT?:

https://www.seguridadaerea.gob.es/en/ambitos/aeronaves/aeronavegabilidad-continuada/otros/guia-de-formacion-en-el-puesto-de-trabajo-ojt

Once the OJT is completed, when you want to incorporate the type rating in the license, the following documentation will be sent to AESA:

• The on-the-job training booklet, which shall include:
  • the name of the applicant
  • date of birth of the applicant; 
  • approved maintenance organisation(s) in which the OJT has been performed; 
  • aircraft rating and licence categories applied for; 
  • list of tasks, including the following: 
  • description of tasks; 
  • reference to the work card/work order/technical registration of the aircraft, etc.; 
  • place where the task has been completed; 
  • date on which the task is completed; 
  • aircraft registration; 
  • name of guardians (including licence number, if applicable); 
  • a signed recommendation from the guardians for the subsequent final assessment of the applicant.
• The final evaluation of the applicant by the evaluator(s).