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Workshop EASA Part-M (aircraft not involved in Commercial Air Transport) Cologne 1 December 2006
Juan Anton
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1. General
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EASA: Rulemaking
Status of EASA texts
Binding; adopted by the legislator under co-decision; included in Regulation Binding; will be adopted by the Commission following an Opinion from the Agency Not binding; adopted by the Agency.
Guidance Material:
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2. Part-M
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Article 7(3)(a) to Commission Regulation 2042/2003 establishes that, Member States may elect not to apply the provisions of Annex I (Part-M) to aircraft not involved in commercial air transport, until 28 September 2008. See Opt-Out table: (http://www.easa.europa.eu, Rulemaking, Opt-outs to regulation)
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Part-M Section B
This section establishes Administrative requirements to by followed by the competent authorities in charge of the application and enforcement of Section A.
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correctly installed and serviceable; The airworthiness certificate remains valid; The maintenance of the aircraft is performed in accordance with the approved maintenance programme.
operational certificate (other than Commercial Air Transport), the contract with the CAMO and with an approved maintenance organisation is mandatory.
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satisfactory accomplishment of the pre-flight inspection. The inspection must be carried out by the pilot or another qualified person but need not be carried out by an approved maintenance organisation or by a Part-66 certifying staff. Pre-flight inspection is intended to mean all the actions necessary to ensure that the aircraft is fit to make the intended flight (see AMC M.A.301-1).
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Every aircraft shall be maintained in accordance with a maintenance programme approved by the competent authority. It must be reviewed and amended accordingly. When the aircraft continuing airworthiness is managed by a CAMO the maintenance programme and its amendments may be approved through a maintenance programme procedure established by such organisation (indirect approval). The procedure must be approved by the authority.
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This only requires copying TC holder information but could induce extra costs. This will allow all existing national practices to continue, such as LAMS (Light Aircraft Maintenance Schedule) in the UK or AC extending piston engine overhaul limits. The owner may define himself other time limits acceptable to the NAA. This will allow practices in force in certain countries to continue in a more formalised manner.
NAA recommendations
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For general aviation the existing system of log books satisfies the intent of this paragraph, as far as the airworthiness records are concerned.
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The person or organisation maintaining the aircraft shall have Maintenance data is:
Any applicable requirement, procedure, standard or
access to and use only applicable maintenance data in the performance of maintenance including modifications and repairs.
information issued by the competent authority or the Agency. This allows national systems to continue and enable EASA to produce standards. Any applicable airworthiness directive; Applicable instructions for continuing airworthiness, issued by type certificate holders, STC holders and any other organisation that issues data in accordance with Part 21.
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equipment and material specified in the maintenance data. OWNERSHIP OF THE TOOLS IS NOT NEEDED
organised and clean in respect of dirt and contaminations. OWNERSHIP OF A HANGAR IS NOT NEEDED
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Subpart E Components
A Decision is very close to publication to declare as standards parts all non required equipment on gliders. Non salvageable parts must be mutilated beyond repair before they are disposed of. This is important to limit the number of bogus parts. Maintenance on components must be performed by Subpart F or Part 145 organisations. However, certifying staff qualified in accordance with M.A.801(b)(2) may perform maintenance on components while they are installed on the aircraft.
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A maintenance organisation may maintain any aircraft and Alleviations for general aviation:
No quality system. Organisational Reviews are allowed
per M.A.616. No ownership of tools, data and facilities.
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Subpart G Continuing Airworthiness Management Organisation (CAMO) An approved continuing airworthiness management organisation may manage the continuing airworthiness of non-commercial air transport aircraft as listed on the approval certificate. The CAMO may be authorised to approved the maintenance programme itself. The CAMO may be approved to issue the airworthiness review certificate. Alleviations for general aviation: No quality system needed if no ARC privilege is held (for small organisations) No ownership of data and facilities
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A certificate of release to service shall be issued before flight at the completion of any maintenance by: A Part-145 organisation; A Subpart F organisation; A Part-66 licensed engineer for non-complex tasks (see Appendix VII), excluding components off the aircraft; For gliders and ballons this means a national license. A Pilot-owner (per Appendix VIII) Tasks included in the AFM are not considered maintenance tasks, except in those cases where there is an attachment to the AFM showing the maintenance schedule.
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For a pilot-owner a certificate of release to service should contain the following statement: Certifies that the limited pilot-owner maintenance except as otherwise specified was carried out in accordance with Part-M and in respect to that work the aircraft is considered ready for release to service
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airworthiness review must be carried out periodically. This airworthiness review includes a review of technical documentation and the physical survey of the aircraft.
approved organisations this activity is carried out without the intervention of the NAA.
When an aircraft is not in the above case the ARC is issued by the
NAA based on a recommendation from a CAMO, every year.
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Implies changes to regulations related to Initial Airworthiness, Continuing Airworthiness and Maintenance, Air Operations and Pilot Licensing. Changes to Continuing Airworthiness and Maintenance are handled by M.017 group.
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