Frequently asked questions

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?

Under Rating A, simple maintenance of components installed in the aircraft can be done according to the CMM, which can even be disassembled for better access, as long as they do not involve extra maintenance of the aircraft. These tasks are released by the CRS of the aircraft where the component was installed.

Therefore, according to the standard, it is not possible to keep a component under rating A outside the aircraft to be installed on another aircraft, since the standard states that the component must be installed on that aircraft and its maintenance released with the CRS of the aircraft. If the organisation wants to do so, it should ask for the scope of components, even for simple tasks.

• If the component is on condition, it is sufficient provided that block 12 indicates the tasks performed in the inspection/test and the maintenance data used (or there is traceability to the documentation where the information can be found).

• If the component is hard time (on condition with maintenance), this Form 1 would only be accepted if block 12 contains information about the last time the corresponding tasks were performed, or if Form 1 accompanies the relevant documentation with the last completion of these tasks. Preferably both.

• If the component is life limited, back-to-birth or back-to-overhaul traceability shall always be required. In case you have an inspected/tested Form 1 you should come in block 12 information from TSN/TSO or CSN/CSO and, in addition, it is accompanied (at least) by the last Form 1 of overhaul or new, or any other documentation clearly demonstrating its traceability to zero.

Certifying or releasing a maintenance task by means of a TLB, CRS or EASA Form 1 is considered to be the last action in the production process of a maintenance facility, and this task is the privilege of the certifying staff duly authorised to do so. A Quality Manager of a maintenance centre, as well as the Quality System auditors, should not be involved in this production process (AMC 145.A.65 (c) 1-11), since when managing/performing quality audits, an essential component of the Quality System, the required independent nature of the quality system would be infringed. 
 
Depending on the size of the organisation in some cases, and in the reverse direction of the case being dealt with, competent personnel, without being quality auditors, are allowed to carry out quality audits of production processes in which they are not directly involved, but it is not admitted that the Head of the Quality System or Personnel Auditor exercises the certification privileges.

Oh, yeah, yeah. In relation to maintenance of aircraft components by an organisation with rating A, maintenance not covered by the AMM and yes by the CMM, Regulation 1321/2014 makes two references: 

1.- Appendix IV to Part M, paragraph 4
It argues that an A-rating organisation can maintain components in the aircraft according to the CMM. 
Limitation: That component must be fixed on the aeroplane and may only be disassembled to improve access to that component during maintenance. Such disassembly cannot generate additional maintenance. This maintenance should be included in section 1.9.1 of the Organisation’s Manual (MOE/MOM) and approved by EASA. 

2.- M.A.502 (b) 
It argues that for this maintenance it is not necessary to issue an EASA Form 1, it is sufficient to refer this maintenance in the CRS (CMM task) of the aircraft.

As provided in point CAMO.A.125(d)(3), a CAMO may organise the performance of limited continuing airworthiness tasks with any subcontracted undertaking, working under its Management System, which shall be included in its certificate of approval (AC-CAMO-P01-F14).
Tasks that can be outsourced include reliability control and engine health control (reliability monitoring & engine health monitoring). 
However, when these tasks are entrusted to the manufacturers or owners of the aircraft or engine designs and their feedback is limited to reporting to CAMO the reading of the data provided, it will be considered as non-subcontracting and, therefore, will not be included in the CAMO approval certificate.

“Details of maintenance work performed” according to GM M.A.305(g) are the records that must be maintained by the person or organisation responsible for the continuing airworthiness of the aircraft in accordance with M.A.201 in order to be able to fulfil its obligations under Part M. They are only part of the records referred to in points CAO.A.090(a) or 145.A.55(a).
Maintenance organizations must keep all detailed records to demonstrate that they have worked in accordance with their respective requirements and procedures.
It is not necessary to transfer all records from the maintenance organisation to the person or organisation responsible for the continuing airworthiness of the aircraft in accordance with M.A.201, unless they specifically contain information relevant to the configuration of the aircraft and its future maintenance. Therefore, it is not necessary for the person or organisation responsible in accordance with M.A.201 to keep the certificates of conformity, the references to the batch numbers of the material used or the individual work cards verified and/or generated by the maintenance organisation. However, the owner/CAMO may request such information from the maintenance organisation to verify and demonstrate the effectiveness of the aircraft maintenance programme.
Information relevant to future maintenance may be contained in specific documents related to:

• amendments;
• airworthiness directives;
• repaired and unrepaired damage;
• components mentioned in M.A.305(d); and
• measures relating to defects.