- Is it possible to maintain a component without issuing a Form 1 when it is going to be used by the same organisation?
- 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
RESPUESTA DE EASA
The following aspects to be taken in consideration:
- What kind of tasks can a B1 perform in a transponder checkup?
- Use automated testing equipment (which does not require previous calibrations)
- Test results are GO/NO GO
- Be trained in the use of such equipment.
A B1 can perform transponder check tasks, as long as:
- Clarifications about pilot-certifiers
- 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”)
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):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.
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