Frequently asked questions

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.

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.

Relevant training serves to reduce the basic experience requirement to obtain a Part 66 LMA license.

Relevant training shall be considered:

• Higher-grade vocational training courses in the following specialties:
  • Superior Technician in Aeromechanical Maintenance (for B1).
  • Superior Aviation Maintenance Technician (for B2).
     
• Higher grade training courses in maintenance of the following specialties:
  • Aeromechanical turbine engine aircraft (for B1.1).
  • Aeromechanical of piston-engine aircraft (for B1.2).
  • Aeromechanical turbine engine helicopters (for B1.3).
  • Aeromechanical of piston-engine helicopters (for B1.4).
  • Electronic and avionic systems in aircraft (for B2).
     
• Training corresponding to a basic training course in a subcategory of B1 other than that requested in an organisation Part 147.

However, the consideration of relevant training does not exempt from passing the examinations corresponding to the basic training modules of Part 66 of the category or subcategory of the licence that is intended to be obtained.

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.

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

The process of transferring one license to another authority is as follows:

1. The holder of a licence issued by AESA intending to transfer his licence to an authority other than that which issued the first licence (AESA), shall request the transfer of his licence to the new authority.

2. It must be the Authority of that country that contacts the Spanish Authority through an official request for transfer, via email.

3. A “licensing verification” format is required. Once completed by the SLFTM, it will be sent to this Authority via email.

4. The email indicates that until the original License is received in the Spanish Authority, the complete file will not be sent. Such License must be submitted either by the applicant or the Authority by registered mail.

5. Upon receipt of the Original LMA License, the applicant’s entire file will be sent, via email, to the Authority of the country to which the license is intended to be transferred.

6. The process is closed when the Authority of that country sends a letter indicating that the process has been completed by issuing the new AML. At that time, the Spanish License is revoked.

According to point 66.A.30(e) and its relevant AMC, aircraft maintenance experience obtained outside a civil aircraft maintenance environment shall be accepted, where such experience is equivalent to that required by this Annex (Part-66) established by the competent authority. However, additional experience in civil aircraft maintenance will be required to ensure adequate knowledge of the civil aircraft maintenance environment. This experience shall be for category A at least 6 months and for categories B1, B2 and B3 of 12 months.

Training can be provided in English as long as staff and documentation are prepared for it.

In Spain, as a member of ICAO (Instrument of Ratification published in BOE No. 55 of 24 February 1947) and of the European Union (Instrument of Ratification published in BOE No 1 of 1 January 1986), the SAFA/SACA Inspections are part of the Rampa Inspection Programmes developed by ICAO from which the European Commission’s SAFA Inspection Programme was derived, after which EASA extended it to air carriers within the EU with SACA inspections.

The main regulations that apply to SANA Inspections are as follows (listed not exhaustive):

a. INTERNATIONAL AND EUROPEAN FRAMEWORK:

(1) Chicago Convention on International Civil Aviation of 1944, Article 16. Aircraft inspection; and its derivative Annexes
2) Regulation (EU) 2018/1139, Chapter IV, Article 62 and its derived technical regulations, including:

I. Regulation (EU) No 965/2012, Annex II, Subpart RAMP;
II.    Regulation (EU) No 1321/2014,
iii.    Regulation (EU) No 1178/2011,
iv.    Regulation (EU) No 748/2012,
v. Regulation (EU) No 923/2012,

B. NATIONAL MARCO

1) Law 21/2003 of 7 July 2003 on Aviation Safety;
(2) Law 48/1960 of 21 July on Air Navigation;
3. Royal Decree 98/2009 of 6 February 2009, Aeronautical Inspection Regulations; and
4) Law 39/2015 of 1 October 2015 on the Common Administrative Procedure of Public Administrations.
5) Royal Decree 184/2008 of 8 February 2008 approving the Statute of the State Aviation Safety Agency
6) Technical regulations, including:

I. RD 750/2014
ii.    RD 384/2015
iii.    Technical standard of ULM.

The detail for the execution of ramp inspections is developed by the European Aviation Safety Agency (EASA) in EASA’s Rampa Inspection Manual, which details inspection instructions and procedures.

The rules on flight time limitations and rest periods, as set out in Subpart ORO.FTL, apply to flight and cabin crew members. In addition, in cases of carriage of cargo in the passenger cabin, it is also required to be applied to cargo surveillance personnel in flight.

However, there is no specific similar legislation applicable to land workers, the labour regulations and collective agreements being applicable.