Frequently asked questions

As provided in regulatory points M.A.403(b) and ML.A.403(b)(2), as applicable, the pilot may defer a defect in accordance with the MEL as long as it does not require the performance of a maintenance procedure (M), as it is not considered maintenance, and no commissioning or CRS is required.

For the rectification of an already issued CRS, the following points must be taken into account: 

• It's not a new commissioning. 
• the name of the person correcting the record and the date of correction, which may be another TMA or Technical Office staff, as established by the maintenance organisation in its manual.  
• The original record and the name and number/stamp of the certifier that gave the original CRS must be legible.

As set out in paragraph 145.A.30(j)(1) and (2) and Appendix IV to Part 145, the holder of an ICAO licence shall demonstrate that he has acquired the training on human factors and airworthiness regulations detailed in modules 9 and 10 of Appendix I to Part 66, and the aircraft type training indicated in point 1(e) of Appendix IV, which shall be equivalent to that in Part 66 and for which such a comparison shall be made. 
 
Further information can be found in the following table provided by EASA.

NOTE: after BREXIT Part 66 licences issued by the United Kingdom are considered national licences under 145.A.30(j)1 and 2, and may be used under the conditions of Appendix IV to Part 145. 

Please note that C/S or S/S authorisations issued on the basis of "foreign domestic licences" MAY NOT be used within the territory of the EASA Member State (neither for line operations, nor for base operations, nor for air flight operations (AOG) nor for occasional line maintenance). The only exception to this is 145.A.30(j)(5).

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.

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).