FAQ

On the following pages you'll see an overview of all available FAQ entries.

Aviation Training

Should this "maintenance experience" be the same in all 145-organisations due standardisation?

No, it depends on the scope of the Part-145 approval and on the Part-66 licence holder.

Status of Part 66 for Components? Release of Aircraft within small organisations? Notification of changes in regulations?

  1. For the time being there is no specific licence for components: Work planned to start as of 2008. The result of the working group is not yet known and EASA is waiting for final result.
  2. See Part-M Subpart F
  3. For the time being there is no automatic system to notify changes in regulations. We suggest you to visit EASA website regularly.

Please give a proper interpretation of "maintenance experience"?

The Organisation shall ensure that all certifying staff and category B1 and B2 support staff are involved in at least six months of actual relevant aircraft or component maintenance experience in any consecutive two year period. For the purpose of this paragraph involved in actual relevant aircraft or component maintenance means that the person has worked in an aircraft or component maintenance environment and has either exercised the privileges of the certification authorisation and/or has actually carried out maintenance on at least some of the aircraft type systems specified in the particular certification authorisation.

Recent experience requirement are placed both in Part-66 and Part-145 as they are the responsibility of both the license holder and the maintenance organisation issuing certification privileges. Both cases require 6 months of relevant experience. This is more developed in Part-145 and it is clearly not the intent to require such experience on each aircraft type. What is understood as 6 months experience is detailed in Part- 145.A.35(c). In the case of isolated certifying staff, the requirement is more stringent as we only have the Part-66.A.20(b)(2) since there is no system to accompany the certifying staff.

CAMO (EASA Part-M)

In M.A.403 is stated that a pilot can defer defects according the M.E.L., should those deferred defects been certified by Certifying staff so the aircraft therefore can be considered ready to release to service?

Based on M.A. 403(b) a pilot may decide to fly or not, by deferring defects within the limits of the MEL. M-item in MEL require release by certifying staff unless, based on Leaflet 38 (incorporated in Part- 145), flight crew is authorised for the release.

What are the implications of Part M for very small operators (3 – 5 persons)?

No change from Jar-Ops 1 Subpart M.

Will Part M also be applicable to Corporate / Business Aviation?

Yes, Part-M applies to all maintenance activities within civil aviation.

Is it possible to be approved according to Part M, independent of an AOC-holder or a PART 145 approval?

Yes, you can be approved as a Part-M Subpart F and G organisation for non-commercial and small aircraft.

If the pilot or a qualified mechanic is performing the Pre-flight inspection, he has to verify all outstanding deferred defects in the Tech-log for validation and repetitive required maintenance actions, are those actions to be considered as maintenance? If so, should those items certified by certifying staff?

Verifying all outstanding deferred defects as part of the pre-flight inspection is not considered as maintenance (ref. Regulation (EC) 2042/2003 Art. 2(h)).

(145.A.35 Certifying staff and category B1 and B2 support staff (b) Excepting those cases listed in 145.A.306) the Organisation may only issue a certification authorisation to certifying staff in relation to the basic categories or subcategories and any type rating listed on the aircraft maintenance licence listed in Part 66, subject to the licence remaining valid throughout the validity period of the authorisation and the certifying staff remaining in compliance with Part 66.)

Maintenance (EASA Part-145)

Could there be a standardisation for the layout of the "145-certification authorisation"?

The choice in Europe has been made to standardise the lay-out/ contents of the Aircraft Maintenance Licence issued by Authorities but not to standardise the certification authorisation issued by the Part-145 Approved Maintenance Organisations.

In Part-145 there is no requirement for personal tools used by mechanics and certifying staff, are there any requirements?

The requirements for tooling for Part-145 approved maintenance organisations are laid down in para. 145.A.40 and the means of compliance are laid down in the associated para. AMC 145.A.40. This also covers personal tooling, as long as it comprises tooling in official use within the Approved Maintenance Organisation.

Does every component build out temporary of the aircraft for a simple repair; need an EASA Form 1?

Depending on the Approved Maintenance Organisation’s internal release procedures defined in the exposition. When an approved maintenance organisation maintains a component for its own use, an EASA Form 1 may not be necessary. If the maintained component is for a customer/third party, an EASA Form 1 is required.

145.A.60 and Directive 2003/42/EC: Does this EU Directive supersede Part 145.A.60?

No. Both have different objectives – the report under Part-145 is to allow the Agency and the competent authorities to fulfil their regulatory tasks in regard to products and organisations under their regulatory oversight. Report under the Directive is to allow the wider aviation community, in particular independent investigation bodies, to have a view of the overall safety level, identifying safety gaps and exercising political control over the systems.

Directive 2003/42/EC: In the EU Directive, is clearly mentioned what the definition of an occurrence is, should this definition not be the same for Part 145.A.60?

Part-145 contains (external) occurrence reporting (145.A.60(a)) and an internal occurrence reporting system (145.A.60(b)). If the implementation of Part-145 shows the need for clarification, a rulemaking activity would be launched to complement Part-145 and/or its AMC on this point.

If this maintenance is for example a (cabin) inspection, how is it possible for the certifying staff to verify this inspection by the mechanic?

It has not been described in detail how this should be done. There are several ways of verification that all maintenance ordered has been properly carried out by the approved maintenance organisation. Important is that the certifying staff have ensured this and thus can issue a CRS for the maintenance activities performed.

If a qualified mechanic is approved by the 145-organisation for inspection, which inspection checks are in his/her scope?

An inspection is a maintenance task.

If qualified mechanics are approved to perform maintenance tasks, which tasks is PART-145 referring to?

An inspection is a maintenance task.This is to be determined by the 145 organisation through the MOE. Furthermore, the mechanic does not necessarily need to be approved for inspections.

Is there a possibility in the PART-145, for non-support or noncertifying staff for example a qualified mechanic to perform an "inspection"? Note: we are not referring to Pre-flight, or NDT inspections

An inspection is a maintenance task.Yes, if the company has procedures not all inspections have to be carried out by support or certifying staff and therefore a qualified mechanic can perform an "inspection", B1 or B2 must “ensure” that the inspection has been carried out properly.

If the words "all relevant" are also in relation with "inspections", does this mean that only the cat B1 or B2 certifying staff shall ensure that this relevant inspection has been carried out to the required standard?

However, non-support staff, for instance "qualified mechanics", could ensure the non-relevant inspections. Of course, what those "relevant tasks" are is for the National CAA's to decide. The question of who carries out these inspections depends on the company procedures. If the company has well structured procedures not all inspections have to be carried out by certifying staff. Certifying staff has in this case to ensure that they have been carried out properly.

Please give a proper interpretation of PART 145.A.30 phrase (h)1 (i)?

"B1 and B2 support staff shall ensure that all relevant tasks or inspections have been carried out to the required standard before the category C certifying staff issues the certificate of release to service". The differences in interpretation are the words "all relevant". Does the words "all relevant" shall be used by "tasks" only, or does the words "all relevant should also be used by "inspections". If the words "all relevant" are not in relation with "inspection", this means that only the cat B1 or B2 certifying staff shall ensure that this inspection has been carried out to the required standard. This means also that qualified Mechanics are not approved to perform an inspection in Base Maintenance.

“All relevant” relates to tasks and inspections carried out for maintenance. Refer to the definition of maintenance in Art. 2(h) of Regulation (EC) 2042/2003.

If tasks are defined by the 145-organisation, should there be a standardisation of those tasks in all 145-organisations?

No, this depends on the scope approval of the Part-145 organisation and its internal structure.

Trouble shooting is a part of maintenance, if a deferred defect has been raised by means of trouble shooting should this defect therefore been certified by certifying staff?

After the performance of trouble shooting, a CRS shall be issued by appropriately authorised certifying staff after performing correction activities. The same applies for defect rectification.No, this depends on the scope approval of the Part-145 organisation and its internal structure.

What is the maximum of aircraft type-ratings approvals allowed on the 145- certification authorisation?

It depends on the scope of the Part-145 approval and on company procedures. The scope should be equal or less than both the scope of the Part-145 and of the licence holder.

Is troubleshooting to be performed by Certifying staff?

Part-145 does not require certifying staff to carry out trouble shooting. Nonetheless, it does require B1 or B2 certifying staff to release maintenance after such trouble shooting.

AMC 145.A.30(g) point 2(p): Does item "p" means that a cat "A" certifying staff is allowed to defer defect in the Aircraft tech log, and are they allowed to deactivate all severe safety systems? Or is he/she allowed to defer defects of all complaints outside the cat A scope in relation of the M.E.L.? If a "cat A" AML holder can defer defects, is he/she only allowed to defer defects in his scope as stated in AMC 145.A.30 (g)?

Cat. A certifying staff is only allowed to defer defects for activities which are within his scope of certification authorisation. It has to be agreed by the competent authority.

Only certifying staff are able and can decide of the aircraft may fly or not.

AMC 145.A.30 does not exist. Nonetheless, M.A.403 does refer to Part-145 and therefore those described in paragraph 145.A.30.