Frequently asked questions

In which cases can component maintenance with rating A be performed?

    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.

Is it acceptable to have only one “inspected/tested” Form 1, without any other historical, to install a component?

    • 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.

Can the Quality Officer of an organisation Part 145, with certification authorisation with scope of basic maintenance (Category LMA license), sign the CRS for basic maintenance work?

    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.

Can a maintenance organisation with rating A perform component maintenance on the aircraft, not covered by this component maintenance by the AMM and yes by the CMM?

    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.

Is it possible to maintain a component without issuing a Form 1 when it is going to be used by the same organisation?

    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
What kind of tasks can a B1 perform in a transponder checkup?

    A B1 can perform transponder check tasks, as long as: 

    • Use automated testing equipment (which does not require previous calibrations)
    • Test results are GO/NO GO 
    • Be trained in the use of such equipment.
Clarifications about pilot-certifiers

    A) Preflight inspection vs “preflight” interval maintenance inspection
    Some TCH (usually helicopters) include in the maintenance documentation inspections with interval “preflight” or “before the first flight-BFF”. The content of these inspections is usually similar to the content of the pre-flight inspection included in the aircraft flight manual (AFM). The criterion to be applied in order to register its completion is:

    In cases where the maintenance documentation (SMM, AMM, etc.) and the flight manual (AFM) include identical tasks, it is considered acceptable for the pilot to carry out inspections under the operation umbrella (signing the pre-flight inspection section) without having to perform a Maintenance “Release”. Normally this will not happen, as there are usually modifications incorporated into the aircraft that include pre-flight inspections linked to the Maintenance Manual.

    B) Pilot-certifiers in approved line stations
    Here are some criteria on how to deal with pilot-certifiers when certifying tasks in approved line stations (lines included in the MOE):

    • There needs to be a Part 66 certifier assigned to the line.
    • The availability of the Part 66 certifier to attend the facilities should be clearly identified in the production plan when necessary.
    • The pilot-certifier can only certify simple tasks (mainly ALF, BFF, TA) to perform tasks according to 145.A.30 j) 4) since the certifier is not full time in the installation (at the moment the installation would be treated as “not supported”)

    The following link to the EASA website  is included as an additional reference.

     

Performing critical tasks as a certifier in the first year

    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.

Roles and responsibilities of maintenance managers

    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?

Can a component with no history with an EASA Form 1 marked Inspected/Tested be installed on an aircraft?

    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.