Frequently asked questions

Clarification regarding continuous training of certifying and support staff in 145.A.35.

    Part-145 does not require continuous training for certifying personnel in the fleet. The required course in new technologies does not have to be focused on an aircraft, but on new tools, test methods, software, etc. Therefore, it does not have to be an aircraft course and yes of these new techniques. If the same new technologies have been developed for an aircraft similar to the range, a course on that aircraft covering them would be valid.

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.

Is a Form 1 required for the conformity of a component of a new aircraft?

    The conformity of a component/element of a new aircraft is included in that of the complete aircraft, so it is not necessary to have a Form 1.


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.

What license is required to perform avionics tasks on aircraft less than 2 000 kg?

    The current regulations do not provide for B2 licences for aircraft under 2000, therefore, for all avionics tasks which, due to their complexity, cannot be performed by a B1 with the rating of the aircraft or the group, they can be carried out by a B2 licensed mechanic with the rating of another aircraft.

What employment relationship is acceptable to a Quality Manager?

    the Quality Officer must maintain a direct contractual relationship with the maintenance organisation.


What requirements should a work order management and maintenance review system or software meet at a Part 145 maintenance facility where the role of the entire process is intended to disappear?

    The procedure for managing the organisation’s maintenance documentation should be indicated and detailed in sections 2.8 and 2.13 of the Organisation’s EOM Manual. It should be clear how the user performs access to the system (user and password, card reader, ID card, etc.), as well as the traceability of what staff (TMA, certifiers, etc.) do, i.e., as applicable, should remain “footprint” of who, how, when, what, etc.

Who has the ultimate responsibility for the installation of components without history?

    The ultimate responsibility for checking the documentation and status of a component before installing it is always the one who installs it, i.e. the P145. If the aircraft or component is under the control of a CAMO, it is the responsibility of the CAMO to provide the P145 centre with the traceability documentation of that component.