EASA PART 145 CONTINUATION TRAINING

Transcription

1 EASA PART 145 CONTINUATION TRAINING DATED: April 2012 Page 1 of 11

2 CONTENTS: 1 Introduction 2 Focus on the MOR scheme 3 UK Information Notices 4 Company Documentation Changes 5 Important changes to Part 66 6 Important changes to Part News 8 CAA audit findings 9 Focus on Component Acceptance Page 2 of 11

3 1. Introduction The purpose of the Part 145 continuation training is to keep ALT Engineers and Mechanics up to date with regulatory issues, the things that affect the industry, licensing and our organisation in-particular. This will cover recent Quality memos regarding the day to day issues that have arisen and also cover relevant audit findings that have been highlighted by the ALT Quality department along with the Operator s quality audits. 2. Focus on the MOR scheme A few questions have recently been raised regarding the need to report technical deficiencies through the MOR scheme. Some of the UK engineers will no doubt remember that the CAA published CAP 382 which detailed the old reporting requirements from the British requirements. Although that CAP is still a valid document, the legal requirement to report is contained in EASA PART 145.A.60 and the mandatory element of it is worded as follows: The organisation shall report to the competent authority, the state of registry and the organisation responsible for design, any condition of the component or aircraft identified by the organisation that has resulted or may result in an unsafe condition that hazards seriously the flight safety AMC (Acceptable Means of Compliance) 20-8 then further details some examples of items that need to be reported in line with the criteria specified above. A link to the AMC is below and can be found on SharePoint in the regulatory links pages. From an ALT perspective, any MOR reports should be completed and forwarded to the Quality Manager. This is simply to ensure that the content is checked before being sent and also to ensure that the ALT MOE requirements are complied with regard to notifying the design organisation, operator, UK CAA Safety Data & the UK CAA local office. Recognising the Engineer s entitlement to submit those reports, even where it is felt that the report does not meet the MOR criteria, if the Engineer still feels that it should be submitted then it will be. RM/decision_ED_2003_12_RM.pdf Both of the documents referenced above can be found on SharePoint. Page 3 of 11

4 MOR Flow Chart 3. UK CAA Information Notices Regional Office Review Some of you may be aware that in April, our local CAA office closed and the staff have relocated to the Luton office EU / US Bilateral The oversight of EU based FAA approved Repair Stations is transferring to the EU Competent Authorities. In the UK, this responsibility is transferring to the UK CAA whose Surveyors are undertaking training. The notice gives details relating to the transition as it affects UK organisations Changes to the UK CAA Website Details recent and proposed changes to the UK CAA website There were no applicable UK CAA Safety Notices or EASA Safety Information Bulletins for this period. All of the documents referenced above can be found on SharePoint. Page 4 of 11

5 4. Company Documentation Changes The MOE has been amended twice this period and is now at Revision 7. Revision 6 included the A (BGY) and Revision 7 the B (LGG). In addition, Revision 7 allowed for the use of recency letters from previous employers for new approvals. Corresponding changes have been made to the Technical Procedures, now also at Revision 7. Temporary Revision 12 has been issued for the MOE to cover some limited scope work at Kemble. It should be remembered that although A approvals have been issued outside of BGY, only BGY is approved for the type so no scheduled maintenance can be accomplished at other locations. Something to be aware of is changes to the Type Board Exam process. We have extended the list of examiners and introduced a little more flexibility into the system. In addition the number of people on the board has been reduced to two, again to make the system a little more flexible. Although we have made changes to the system, the system is well conceived and intentioned. Our only consistent problems with the approval system have been as follows: We get a TBE but no assessment sheet (they should come together) The TBE sheet just states satis We receive incomplete applications All of the above lead to delays in applications being processed although it is acknowledged that the requirements are not always as transparent as they could be. This will be remedied over the Summer months. Page 5 of 11

6 5. Important Changes to Part 66 You may be aware of European Commission Regulation No. 1149/2011 which amends Part 145 & Part 66. The amendment introduces the B3 License for Light Aircraft in some respects equivalent to the old BCAR Section L Aeroplanes 1 & Piston Engine licenses. The change also amends the scope of the B2, the biggest change being the extension of the scope to allow B2 Engineers to be authorised by the Part 145 to certify Cat A level tasks without the need to actually hold a Cat A license. This extension in scope is limited to work the B2 has performed in person and will require some changes to the MOE before it can be used by ALT. Unlike the Cat A, this extension in scope will only be applicable for the types for which the B2 Engineer is already type rated. There is additional experience required by the rule although at first glance it looks as though none of these are going to be an issue for ALT engineers. In addition to the above, the scope of the B2 has been extended to cover electrical tasks within power plant and mechanical systems requiring only simple tests to prove serviceability. Basic training credits / Modules are valid for 10 years and type training will only be valid for 3 years. For those sitting on unspent Part 147 type training certificates over 3 years old, you may well find that they will no longer be accepted and indeed we have had at least one rejection partially on that basis already. Good advice is to submit any type rating applications as soon as possible. There are changes introducing a requirement for approved OJT / Practical Training in order that a new type can be added to a license. Informal communication from the CAA confirmed that the days of collecting worksheets in an ad-hoc manner to support a type rating are over and this is reflected in the regulation change. The date being pushed at present is the 1 st August this year but we are expecting official communication from the CAA and will pass that detail on as soon as we receive it. Other changes to Part 66 introduce some additional requirements for the B2 to cover during type courses. This appears to be linked to returning some B1 electrics privileges to the B2 as it covers a lot of airframe / engine and associated electrical & instrumentation changes. Page 6 of 11

7 6. Important Changes to Part 145 Decision 2011/011/R introduces changes relating to the control of contracted personnel. In addition and perhaps the most major change is a change to the requirements for establishing competence. EWIS is now specifically mentioned in the AMC to Part 145. Inevitably changes will be required by ALT to achieve compliance with the rule. These changes will be put in place over the Summer months at which point, more information will be promulgated. 7. News See the following web address for further information regarding ACL procedures: Web address: Username: HEAVYLIFTTL Password: rag5288bsk This is a further URGENT reminder to engineers who have approvals to ensure that you have your own validated means of proving your work experience. This means worksheets / logbook as appropriate. The SMS is still under development and is planned to be fully functional by the end of All engineers and mechanics are encouraged to get involved in our safety system. Trish Hunter has been promoted to Quality Administration & SMS Manager reflecting the additional responsibility for the implementation and day to day management of the SMS. The subject of SMS is becoming increasingly important with our customers and this is an important role. We wish Trish every success in her new role. 8. CAA Audit Findings We have been subject of one audit from the CAA during this period. The audit related to the addition of the B747 to the Liege Line Station Scope of work. There were no adverse findings. We had one observation relating to our handovers and some content is included in the HF module giving you more detail. Page 7 of 11

8 The next scheduled routine UK CAA audit is expected to be carried out in BGY. 9. Focus on Part 145.A.42 Component Acceptance A recent customer audit finding highlighted that for Engineers holding approval for stores functions there is no special training designated. As a result, the requirements for the acceptance / inspection of components are summarised below. The applicable rules / procedures are as follows: EASA Part 145.A.42 Acceptance of Components (and associated AMC) ALT MOE 2.1 Supplier Evaluation and Sub-contract Control Procedure ALT MOE 2.2 Acceptance / Inspection of Aircraft Components & Materials from outside contractors Applicable Customer Requirements as detailed in applicable ALT line station TP Part 145.A.42 requires that all components shall be classified and appropriately segregated into the following categories: Serviceable // Unserviceable // Unsalvageable (scrap) // Standard parts // raw material. The rule requires that components (not standard parts or raw materials) in a satisfactory condition are covered by an EASA Form 1 or equivalent as follows: Page 8 of 11

9 For components that are not new (i.e. used) and have been worked on by another PART 145 approved organisation based outside the EU, a common release document will be an FAA or Transport Canada Form 1. In this instance, for installation on an EASA registered aircraft, an EASA Part 145 release to service must be evident. This is commonly referred to as a dual release. When accepting parts in this manner, it is important to ensure that the EASA Part 145 release has been applied by the issuing organisation ticking the other release block and the Part 145 approval details appearing in block 12. If the EASA release to service is not evident for a used / maintained part, then it cannot be installed on an EASA registered aircraft. In summary, if a non-new (i.e. used) component does not have an EASA release, it cannot be installed. It is worth noting that for used / maintained parts, the above applies even to aircraft manufacturers own repair stations. The fact that they manufactured the aircraft gives no special privileges in this regard. For acceptance of standard parts and raw material, AMC 145.A.42 (a) 2 refers you to EASA AMC M.A.501 (c) & (d). With regard to standard parts, AMC M.A.501 (c) gives the following definition and requirements: Page 9 of 11

10 With regard to consumables and raw materials, AMC M.A.501 (d) gives the following definition and requirements: These requirements are reflected in the Altitude Global MOE Part 2.1 & 2.2. ALT MOE 2.2 also requires that all components, parts and material are inspected upon receipt for damage or deterioration. Clearly this physical inspection requires the item to be unpackaged. For components that are marked as ESDS items, appropriate precautions must be observed as detailed in the line station Technical Procedures. The airworthiness status of the component / part as described on the release document is such as to permit its use i.e compliance with mandatory airworthiness requirements (such as CDCCL items) / modification status (usually indicated by IPC at a component level). Items not meeting the requirements are to be quarantined pending investigation and cannot be installed. As recording requirements differ between different ALT stations, the relevant line station TP should be consulted. Page 10 of 11

11 Customer Requirements ALT EASA Part 145 Continuation Training. As the basic rules for the acceptance of components are stated in Part 145 & Part M, a very high level of commonality exists between the ALT and its customers, however, staff should be aware of the customer requirements for the acceptance of components to be installed on the relevant fleets. Indeed this is a requirement of the relevant ALT Technical Procedures. Customer procedures & expositions are available at ALT line stations. Any deficiencies in this area should be reported to the Technical Services Department at STN or detailed on a SIRS report. Page 11 of 11