What is EASA Part-M, Continuing Airworthiness?

Evolution in General Aviation

Juan Anton Continuing Airworthiness Manager Rulemaking Directorate EASA

29 February 2012

Aviation Conference in Norway (Bodo)

What happened in the old times ?

Before the existence of EU rules:

Every Member State had its own national aviation rules.

They covered all aviation aspects: operations, licensing, maintenance, certification, airports, air navigation, etc.

This had the advantage of having all these aspects under the control of the same Member State but it was certainly difficult to move goods/services/licensed personnel between different Member States.
Some Member States had their own bilateral agreements and working arrangements with other states and authorities.

29 February 2012

Aviation Conference in Norway (Bodo)

A first step into standardisation

The first step into standardisation was the introduction of JAA requirements: They covered only certain aviation aspects and only for certain aircraft categories and operations, such as:
JAR-145 JAR-66 JAR-OPS1 JAR-FCL

The implementation was voluntary for each Member State and could only happen if adopted in the national law.

Each Member State had the option to decide whether they wanted to be standardised (through inspections) or not.

29 February 2012

Aviation Conference in Norway (Bodo)

Introduction of EU rules
The Basic Regulation EC1592/2002 (later replaced by EC216/2008):

Created EASA. Established EU requirements for airworthiness, which were of mandatory compliance for all Member States (superseded the national rules).
As a consequence, Implementing Rules were created to cover airworthiness, in particular: Initial Airworthiness (EC1702/2003): Part-21 for Product Certification, certification of Design and Production organisations, issuance of Certificates of Airworthiness, etc. Certification Specifications (CSs) for product certification Continuing Airworthiness (EC2042/2003): Part-M/-145/66/-147.
29 February 2012 Aviation Conference in Norway (Bodo)
4

Continuing Airworthiness rules

How the new Implementing Rules for Continuing Airworthiness were created: Part-145/-66/-147 were relatively easy: They were based on similar JAA rules already existing, with the main difference of introducing Authority Requirements in Section B of each rule. What about Part-M?

29 February 2012

Aviation Conference in Norway (Bodo)

Why Part-M was necessary?

Part-M was necessary because the Basic Regulation EC1592/2002, under the Continuing Airworthiness requirements, covered a much larger range of activities, operations and aircraft categories than the existing JAA rules. As a matter of fact: Part-145 only covered the requirements for the approval of a maintenance organisation and how this organisation performs the maintenance they have been ordered by the owner/operator/CAMO. However, Part-145 did not cover how the airworthiness status of the aircraft is determined, controlled and maintained, how maintenance is planned and ordered and who is responsible for what. The use of a Part-145 organisation was only required for large aircraft and aircraft used in Commercial Air Transport. It was too restrictive for non large aircraft and other types of operations.
29 February 2012 Aviation Conference in Norway (Bodo)
6

What is included in Part-M ?

How the airworthiness status of the aircraft is determined, controlled and maintained, how maintenance is planned and ordered and who is responsible for what. (Subpart-M of JAR-OPS1 was used as a basis and it was adapted to the different aircraft categories and operations) Maintenance standards to be met. Requirements for maintenance organisations involved in the maintenance of aircraft other than large not used for Commercial Air Transport (Subpart F maintenance organisations). For large aircraft and aircraft involved in CAT, the requirements are in Part145. Requirements for independent certifying staff performing certain maintenance for aircraft other than large not used for Commercial Air Transport. Pilot-owner maintenance. Requirements for the renewal of the validity of the Certificate of Airworthiness (airworthiness reviews).
29 February 2012 Aviation Conference in Norway (Bodo)
7

Responsibilities
Main responsibilities of the owner/operator/CAMO:

The owner/operator/CAMO is responsible for the

airworthiness of the aircraft and deciding what maintenance is needed and when and where it has to be performed. maintenance activities when several maintenance organisations are involved.

The owner/operator/CAMO is responsible for coordinating

The owner/operator/CAMO is not responsible for how the

However, the owner/operator/CAMO is responsible for

maintenance is performed. This is the responsibility of the maintenance organisation (it holds an approval). verifying that all the maintenance ordered has been completed and released, as well as for maintaining the corresponding records.
Aviation Conference in Norway (Bodo)
8

29 February 2012

Fundamental aspects of the system

Fundamental aspects of the system: The system is based on a chain of different approvals:

CAMO (Part-M, Subpart G), Maintenance Organisation

Each approval is under the oversight of a competent
authority.

(Part-145 or Part-M Subpart-F), Licensed personnel (Part66), Maintenance Training Organisations (Part-147).

Adequate communication and exchange of information

between competent authorities is essential since there are different authorities involved:

State of Registry, State of Operator, State of CAMO, State of the Maintenance Organisation, State issuing the Part-66 licence.
29 February 2012 Aviation Conference in Norway (Bodo)
9

Fundamental aspects of the system

Fundamental aspects of the system: The system is based on a chain of oversight activities and responsibilities:

The Quality System of the approved organisation.

The oversight performed by the competent authority issuing the organisation approval. The oversight performed by the State where the organisation is located (may be different from the State who issued the approval). Airworthiness Reviews performed on the aircraft for the renewal of the Certificate of Airworthiness. The ACAM (Aircraft Continuing Airworthiness Monitoring) programme of the State of Registry.
29 February 2012 Aviation Conference in Norway (Bodo)
10

Current simplifications (General Aviation)

Simplification for General Aviation:

Regulation EC1056/2008

29 February 2012

Aviation Conference in Norway (Bodo)

11

Current simplifications (General Aviation)

See attached table with different aircraft categories and types of operation.

29 February 2012

Aviation Conference in Norway (Bodo)

12

Future simplifications (General Aviation)

Future simplifications (General Aviation)

29 February 2012

Aviation Conference in Norway (Bodo)

13

On-going work
Standard changes and repairs Opinion 01/2011 (task MDM.032): Currently process of being adopted by the Commission. Task MDM.048 Guidance for TBO (Time Between Overhaul) Task MDM.038 ACAM Task M.027

in

the

Import of aircraft Task MDM.078

29 February 2012 27/10/2011

Aviation Conference in Norway (Bodo) Part-M General Aviation Workshop

14

14

On-going work
Task MDM.048 CS for standard changes and repairs
(similar to AC43-13) ToR published on 28 July 2011. Applicable to aeroplanes up to 5700 Kg MTOM, rotorcraft up to 3175 Kg MTOM, sailplanes , balloons and airships. To be performed in phases depending on the different aircraft categories, starting by the smaller ones. Agency task with support of industry associations.

It is linked to the Opinion issued as a result of task MDM.032.

29 February 2012

Aviation Conference in Norway (Bodo)

15

On-going work
Task MDM.038 Guidance on TBO limits
NPA2011-15 published on 16 September 2011 (3 month consultation).
Covers all type of components installed on non-powered and piston engine aircraft other than complex motorpowered aircraft, when not used for Commercial Air Transport. Very detailed guidance on the inspection procedure to extend the TBO of a piston engine.

29 February 2012

Aviation Conference in Norway (Bodo)

16

On-going work
Task M.027 Guidance for Aircraft Continuing
Airworthiness Monitoring (ACAM) NPA2011-19 published on 29 November 2011 (3 month consultation). This task mostly affects NAAs.

29 February 2012

Aviation Conference in Norway (Bodo)

17

Additional work
The inputs received in the Part-M General Aviation Workshop held in Cologne on 27 October 2011 gave several avenues for extra work:

Standardisation will put emphasis on the level playing field Rulemaking needs to review and simplify the rules EASA needs to work to improve its change management Stakeholders and NAAs should help EASA translate AMCs All should work together to reach a common understanding

29 February 2012 27/10/2011

Aviation Conference in Norway (Bodo) Part-M General Aviation Workshop

18

18

Task Force
A taskforce has been created to address the following: General simplification (Part-M for GA in particular) Handling of modifications Handling of Parts (certificates required) Qualifications and privileges of persons Pilot-owner Certifying staff Persons carrying out reviews Other persons Import/transfer of aircraft ACAM Calendar: Launched in December 2011 Action plan by June 2012

29 February 2012 27/10/2011

Aviation Conference in Norway (Bodo) Part-M General Aviation Workshop

19

19

Task Force (immediate action)

In addition, the Agency must take immediate action in the areas where High costs have been identified No real safety benefit has been identified Quick fixes These areas are the following: Maintenance Programmes Airworthiness Reviews Calendar: Agree within the task force on a fast track process NPA by June 2012 Opinion by end 2012

29 February 2012 27/10/2011

Aviation Conference in Norway (Bodo) Part-M General Aviation Workshop

20

20

Task Force (immediate action)

CURRENT DISCUSSIONS WITHIN THE TASK FORCE: Maintenance Programme (MP): Create, with the help of the Industry, Generic MPs (for sailplanes, balloons, etc). Introduce them in AMC material. Define in the AMC a template for the customized MP: It will refer to the Generic MP (if available) or to the particular documents of the manufacturer (it can work by reference or copying the specific tasks). It will contain the applicable information specific for the particular aircraft (maintenance linked to STCs, modifications, ADs, life limited parts, pilot-owner maintenance, etc. Emphasize the possibility for indirect approval procedure. Annual review of MP at the time of Airworthiness Review.
29 February 2012 27/10/2011 Aviation Conference in Norway (Bodo) Part-M General Aviation Workshop
21

21

Task Force (immediate action)

CURRENT DISCUSSIONS WITHIN THE TASK FORCE: Airworthiness Review (AR): Initial discussion focused on ELA aircraft not used in commercial operations. AR to be performed at the same time as the annual inspection. AR to be performed by Airworthiness Review Staff nominated by the maintenance organization (no need to involve a CAMO or the NAA). Maintain also the option that the AR is performed by a CAMO or the NAA. Allow that the person performing the annual inspection is the same as the one performing the Airworthiness Review (no need for independence).

29 February 2012 27/10/2011

Aviation Conference in Norway (Bodo) Part-M General Aviation Workshop

22

22