Frequently asked questions

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).

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.