- In the case of a Party-CAMO organisation without any contract with an owner or operator, is it necessary for the organisation to develop “basic” or “generic” maintenance programs? What means of compliance can be used for this purpose?
The CAMO Party does not impose a “basic” or “generic” maintenance program; however, in Chapter 1.2 of the CAME the organisation must describe how it will develop the aircraft maintenance program (AMP).
The Part-CAMO is based more on performance than the former part M Subpart G, the organisation has to demonstrate that it is competent for the work to be done. Certain elements such as the “IT tool” for AMP or the experience of staff with AMP can contribute to this goal.
- How should deviations be described in the EASA Form AMP of AMC2 ML.A.302?
- Appendix B:
- When the programme is based on the DAH ICAs, Appendix B is to include the additional tasks to those ICAs. In case it is based on an IPM Appendix B is used to include:
- Certain tasks of the DAH ICAs (e.g. maintenance due to components with limiting life).
- Other supplementary tasks (e.g. due to aircraft operation).
- When the programme is based on the DAH ICAs, Appendix B is to include the additional tasks to those ICAs. In case it is based on an IPM Appendix B is used to include:
- Appendix C:
EASA's response:
The intervals in the right hand column should be as defined in the AMP.
If "YES" is ticked in section 5 of the format, you must list any alternative maintenance tasks to the DAH ICAs taking the MIP as a reference
- Appendix B:
- Incompatibility between airframe and engine related tasks in the maintenance programme.
A properly developed maintenance programme should not contain inconsistencies in the performance of tasks required for airframe and engine continuing airworthiness.
One of the characteristics of a proper maintenance programme is its adaptation to operating times and shutdowns in order to carry out scheduled maintenance without impairing continued airworthiness.
In the EASA environment the engine TC Holder must establish the engine ICAs. Each TC Holder must do the ICAs that correspond to him, so there should be no incompatibilities between airframe and engine ICAs, and in case of doubt, the instructions of both TC Holders (or the most critical one) should be complied with, unless the airframe TC Holder demonstrates that EASA has authorised otherwise.
In NON-EASA environments, aircraft can be found without an engine TC, in which the engine TC was considered as just another piece of equipment when certifying the aircraft type, so each case would have to be analysed.
- Questions related to PRESERVATION: 1. If an aircraft is to be preserved, for whatever reason, is it mandatory to amend the maintenance programme and incorporate preservation tasks into it, or is it not necessary and once preservation is completed the aircraft continues to apply its maintenance programme as normal? 2. During the preservation period, is the aircraft airworthy or not? 3. While the aircraft is under preservation, can it continue to be included in the list of registrations managed by the organisation or should the CAMO remove it from its CAME? 4. And in case an aircraft does not follow its maintenance programme and is not preserved either, is the way to put the aircraft back into service by contacting the manufacturer for instructions?
Answers:
1. there is no requirement to amend the maintenance programme to include preservation.
2. During preservation as such the aircraft will not be airworthy, after completion of the preservation phase with all the tasks marked by the manufacturer for preservation and after completion of all additional maintenance tasks according to M.A.301, the aircraft can be considered airworthy again.
3. Yes, it shall remain included in the organisation's manual as during preservation it continues to be managed by the organisation, despite being un-airworthy.
4. In general, the organisation should consult with the manufacturer and follow their instructions.
- What happens to an approved PM when a "One Business Group" is created with a "Single Group CAMO"?
EASA Response:
If the Authority responsible for the approval of the aircraft maintenance programme remains the same, i.e. the authority of the State of registry of the aircraft, the CAMO may continue to use the programme, unless the programme needs to be modified due to changing operating environments, operation, utilisation, etc.
If the Authority responsible for the approval of the maintenance programme becomes the Authority of another member state, because an agreement is established between Authorities to do so, then it is necessary for the new Authority responsible for the approval of the programme to re-approve the maintenance programme for administrative and legal reasons.
- How should the NR (National Requirements) note in the documentation provided by the manufacturer, e.g. in the MPD, be treated?
Normally, this note is included by the manufacturer in the repository document, Maintenance Planning Document, a basic tool for the operator to draw up the maintenance programme.
It usually refers to regulations or legal requirements, usually non-aeronautical, i.e. industrial or occupational safety requirements at European or national level.
Examples could be: inspection intervals of pressurised gas cylinders, buoyancy of lifejackets, expiry of certain capabilities related to heat protection, impact, ingestion of harmful gases, etc.
If any NR is provided for in the manufacturer's documentation, it should be considered whether such a national requirement exists and, if so, it should be included.
- When does the calendar interval for the next completion of a maintenance task start if an extension is made?
See EASA FAQ n. 19102.
If the TCH includes in its ICAs instructions for the calculation of the next completion, these should be followed.
If not, the date of the next completion will be the expiry date prior to the extension or as agreed with the authority, the final decision must be made by the extension approver.
For Part-ML regulated aircraft, the situation is different when the 1 month tolerance in ML.A.302(d) applies, the following interval will be calculated from the date of compliance (see ML.A.302(d)(1) and AMC1 ML.A.302(d)).
- What is meant by "customising" a maintenance programme?
- Instructions issued by the aviation authority
- Instructions ensuring continued airworthiness, e.g. from type certificate holders, certification specifications, operator initiatives, owner, contracted CAMO, etc.
M.A.302(a) states that the maintenance of each aircraft shall be carried out in accordance with an aircraft maintenance programme.
The same aircraft, operated by the same operator and with the same type of operation may be included in the same maintenance programme.
The maintenance programme for a particular aircraft may have specific or particular tasks or modified in both content and interval of completion as a consequence of repairs, modifications carried out on that aircraft or inspection results. This is a certain type of "customisation" or particularisation.
M.A.302(d) states that the programme must comply with:
Justified acceptance of the above may lead to particularities of the maintenance programme of an aircraft or group of aircraft that constitute "customisation".
"To customise is to particularise for an operator or aircraft or type of operation the requirements for application of a maintenance programme to an aircraft or group of aircraft. The degree of customisation to be applied in each case shall be the maximum possible.
- Who can develop and submit the Maintenance Programme for private aircraft, which do not have commercial operation and are not complex motor-powered?
- B. For Part-ML affected aircraft, from 24/03/2020 maintenance programme approvals will not be carried out by EASA (see Part-ML).
We must differentiate whether the aircraft in question is Part-M or Part-ML affected, therefore:
A) For Part M affected aircraft requiring EASA approval (see following table with all possibilities):
A summary of the provisions of Part-ML and its reliefs from ML.A.201, ML.A.302, ML.A.801 and M.L.A.901 is provided in Part-ML paragraph GM1 ML.A.201 'Responsibilities'.