Frequently asked questions

EASA reply: “Generic maintenance programmes are not required for Part-ML aircraft”

Since a CAO organization only has a single approval, regardless of privileges (maintenance only, continued airworthiness only, or both), it cannot be considered simultaneously small and large. That is, if it were small for one privilege and large for the other, the organization would be considered large as a whole.

According to CAO.A.100(e):

• If the scope of the organization only has aircraft listed in Part-ML (CAO.A.100 and (1)) then the CAO can be considered small, regardless of the number of workers (FTE)
• Other options to be considered small, must meet the following two conditions:

1. The organization does not exceed 10 FTEs involved in maintenance, if such privilege is applicable.
2. And the organization does not exceed the 5 FTEs involved in continuing airworthiness management, if such privilege is applicable.

As a CAO organisation will have only a single approval, independent of the number of privileges (only maintenance, only continuing airworthiness or maintenance and continuing airworthiness), it cannot be simultaneous small and big.

Please see below our interpretation of (CAO.A.100(e)):

- If ‘The scope of the CAO does only contain aircraft covered by Part‐ML’(CAO.A.100(e)(1)) Then ‘A CAO shall be considered as a small CAO’ (regardless of the number of FTE)

If the first condition is not valid, then we have to check how many FTE staff are working.

- To still be considered as a small CAO:

• The organisation does not exceed 10 FTE staff involved in maintenance (if privilege is applicable, CAO.A.100(e)(2))
• And the organisation does not exceed 5 FTE staff involved in continuing airworthiness management (if privilege is applicable, CAO.A.100(e)(3)).

On the AESA website:
https://www.seguridadaerea.gob.es/Organisations/Training Organisations/Maintenance Training Organisations (Part 147)

Information on the approval procedure can be found in the Applicant Information Guide FOR-P147-P01-GU01.

Technical requirements on the Organisation Manual can be found in the FOR-P147-P01-DT01 guide.

In the guide FOR-P147-P01-DT04 you can find the technical requirements on the personnel of the organization

In order to obtain approval 147 by AESA, the head office (headquarter or social headquarters of the company where the financial functions and operational control of the activities are exercised) must be registered in Spain.
If the Head Office is located in another EASA member country, the application for approval shall be submitted to the Aviation Authority of that country.  
If the Head Office is located in another country that is NOT a member of EASA, the application for approval will be submitted to EASA.

Although it is not always mandatory when deferring a defect, a certifying technician must issue a CRS if a prior analysis has been required or a maintenance action has been carried out.

No, as set out in the EASA-FAA bilateral agreement, only FAA Form8130-3 Rebuilt for engine are acceptable, as set out in point 10.11.1.6 “Engines rebuilt by the PAH can be accepted as specified in the TIP associated with Annex 1 of the Agreement.   “Rebuilt Engine” means an engine that has been disassembled, cleaned, inspected, repaired as necessary, reassembled, and tested to the same tolerances and limits as a new item by the production approval holder in accordance with 14 CFR part 43.

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.

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.