EASA PART 145 CONTINUATION TRAINING
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1 EASA PART 145 CONTINUATION TRAINING Q1 & Q Q1 & Q Page 1 of 26
2 CONTENTS: 1 INTRODUCTION 2 UK CAA INFORMATION NOTICES 3 MOE & TP CHANGES 4 B1 ENGINEERS PAC FUNCTION CODE K 5 B1/B2 ENGINEERS PAC FUNCTION CODE T 6 QUALITY NOTICES (FORMALLY MEMOS) 7 SAFETY NOTICES (FORMALLY MEMOS) Q1 & Q Page 2 of 26
3 1. Introduction ALT EASA Part 145 Continuation Training. The purpose of the Part 145 continuation training is to keep ALT Engineers and Mechanics up to date with regulatory issues and the things that affect our EASA Part 145 approval. This will cover recent Quality memos regarding the day to day issues that have arisen and also cover relevant audit findings that have been discovered by the ALT Quality department along with the Operator s quality audits. 2. UK CAA Information / Safety Notices For further information refer to the full documents. IN /031 Release of the ECCAIRS European Reporting Portal, a provision of Regulation (EU) No. 376/2014 on the Reporting, Analysis and Follow-up of Occurrences in Civil Aviation The ECCAIRS European Reporting Portal will become live for MOR reporting in the UK on 1 April 2016 when the existing report forms SRG1601, SRG1602 and SRG1603 will be removed from the CAA website and replaced with a link to the new reporting portal. IN /030 CHIRP The Confidential Human Factors Incident Reporting Programme This Information Notice describes services provided by CHIRP the Confidential Human Factors Incident Reporting Programme that are now available for the whole aviation community based in or passing through the United Kingdom. IN /048 Part 66 Licence: The Acceptance of On the Job Training (OJT) in Support of the First Type Rating This Information Notice (IN) sets out the process for the UK Civil Aviation Authority to receive and process EASA Form 19 engineering licence application forms; for the initial type rating in any category or sub category of a UK CAA issued EASA Part 66 Licence. As part of the Part 66 licence assessment process, the CAA reviews On the Job Training (OJT) work records/work sheets supplied by an applicant. This IN identifies the documentation that is required be submitted to assist with these assessments. IN 2015/084 Licence Requirements for Part-66 Renewals, Additional Categories, Aircraft Ratings and Removal of Limitations Commission Regulation (EU) No. 1321/2014, Annex III (Part 66) requires that an applicant for any of the following licensing services must provide his/her current original aircraft maintenance licence to the issuing authority, together with a properly completed EASA Form 19: To add a category or subcategory To add a rating or remove a limitation To renew the licence in accordance with Part 66.A.40 Q1 & Q Page 3 of 26
4 3. MOE & TP Changes MOE changes for the period are as follows: Issue 2, Rev 9 January 2016 Part Intro Updated to reflect this revision in general. 0.4 TP List updated to include ATH, MXP & DSA Line Station and updated TP 11 for Liege Line Station which now includes TR30 for BRU (non-dhl) Line Station. Part 1 Management 1.1 Re-date of Corporate Commitment 1.2 Re-date of Safety & Quality Policy 1.3 Management Personnel (Non-Form4) a) NDT Level 3 (TT) changed to Mr D Penney b) NDT Manager (Ireland) Mr L O Sullivan Deleted. c) Finance Director changed to Mr V Jones d) Deputy Line Maint Manager (BGY) Mr W Sibbons Deleted Organogram updated to reflect addition of: a) ATH line station TR27 b) MXP line Station TR29 c) BRU (non-dhl) line station TR30 d) DSA line station TR Update of station recourses for: a) ATH line station TR27 b) MXP line Station TR29 c) BRU (non-dhl) line station TR30 d) DSA line station TR32 e) Reduction of staff at BAH from 9 to Addition of facility descriptions for: a) ATH Line Station TR27 b) Bahrain line station TR28 c) MXP line station TR29 d) BRU (non-dhl) line station TR30 e) AOI line station TR31 f) DSA line station TR32 g) Removal of Shannon NDT section due to closure Q1 & Q Page 4 of 26
5 1.8.3 Work Away From Approved Line Stations Temp line station approval changed from 30 days to 90 days Update of Line Station Classifications for: a) ATH TR27 b) BAH TR28 (Downgraded Cat 2 to Cat 3) c) MXP TR29, BRU (non-dhl) TR30 (This includes addition of B747 & B777 line capability) e) DSA TR Update of Aircraft Type/Station Location Listing for: a) ATH TR27 b) BAH TR28 c) MXP TR29 d) BRU (non-dhl) TR30 e) DSA TR32 f) Addition of PW2000 engine to LEJ, BGY, AOI, VCE, BRU (DHL), BSL, OSL, ATH, MLA and MXP TR Removal of Shannon NDT facility. Part 4 Contracted Operators 4.1 Addition of contracted operators - Euro Atlantic Airways, TNT Airways and JetMagic. Part 5 Appendices 5.3 Update/addition of Line Maintenance Locations for: a) Brussels Line renamed Brussels Line (DHL) b) Addition of DSA Line c) Addition of MXP Line d) Addition of BRU (non-dhl) Line e) Addition of ATH Line Temporary Revisions (TR s) to MOE Issue 2 Revision 9: Temporary Revision 35 Temporary Approval for the addition of B737-3/4/500 (CFM56) to Line Station Maintenance Capability for BRU (non-dhl) Temporary Revision 36 Temporary Approval for Amsterdam Line Station, Category 3 with B (RB211 & PW2000) and A (PW4000) Line Maintenance Capability. Q1 & Q Page 5 of 26
6 Technical Procedure changes for the period are as follows: Revision 19 January 2016: TP5 Minor changes to SARS Process TP8 Update of Function Codes for Cat A in para 2 and removal of A/C LRU lists replaced by Part 66.A.20 in regards to B1/B2 licence scope. TP9 Addition of Shift-Task Handover Form ALT-QC-071 to para 3, 4 and 5. TP11 Title change to Liege & Brussels Line Station non-dhl, facilities update, addition of Appendix 1 Operations Manual and various amendments which include BRU-non- DHL & B777 capability for TNT. TP12 Update of para 1 & para 3 to extend temporary arrangements from 3 to 6 months. TP13 Update of para 5 to refer to MOE 1.8, 1.9 & 4.1 for contracted line stations. TP15 Update of para 3b for A/C & Engine approved types. TP18 Addition of B727 & B777 to para 2. TP25 BGY-Addition of para 14.1 in regards to control of company tooling TP26 Update of new Station Line Office AOI, addition of A and addition of para 14.1 in regards to control of company tooling. TP27 Update of contact telephone numbers in para 2, update of facilities in para 3 and 12. TP31 Update of contact telephone number in para 2 and update of facilities in para 3. TP32 Update of BRU Line Station Title to Brussels Line Station (DHL) TP34 Change of Title for Eng Projects Manager to Tech Ops Manager and addition of ALT/QC/79 to para 4. TP35 Update of new Station Line Office VCE and addition of para 14.1 in regards to control of company tooling TP38 Addition of B767, update of Station Line Office and addition of DHL Air to para 1, 3, 7 & 14 TP39 Changes to Management 7.6.1, 7.6.2, 7.6.3, , SARS reporting update addition of Just Culture update to ERP to reflect ERP now on SharePoint. Q1 & Q Page 6 of 26
7 TP40 Update of 2.2 to reflect update of call out list. Addition of 2.3/2.4 station contact numbers. Update of 4.3 to reflect second responders. Update of in regards to ERP pack. Update of 9.1 in regards to training. Re-date of 10.1 signatures. TP42 Addition of Athens line Station TP43 Addition of Malpensa Line Station TP44 Addition of Doncaster Line Station 4. B1 ENGINEERS PAC FUNCTION CODE K It is worthy of note that engineers who have been given approval for dye penetrant inspection of materials through the allocation of function code K are done so by the derogation in PART 145.A.30(f) as extract below:- By derogation to the point above, this document does not apply to colour contrast dye Penetrant tests carried out by appropriately type rated B1 Aircraft Maintenance Engineers using the derogation detailed in Part 145.A.30 (f). Note: TP36 Technical Procedure document is based on the requirements of Part 145.A.65 and forms the NDT Manual as described in UK CAA, CAP 747, Generic Requirement 23. To this end it is additionally worth referring to TP 36 para 8 for the use of Dye penetrant inspection, the TP 36 extract is contained below. Q1 & Q Page 7 of 26
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14 5. B1/B2 ENGINEERS PAC FUNCTION CODE T Recently Altitude Global has added function code T to Personal Authorisation Certificates PAC. This is detailed in 3.15 PART 66 Appendix III on the job training of the MOE. The following notes extracted from the MOE summarise the supervisors/engineers responsibility:- a/ It is considered that any ALT Licensed Engineer, type rated and authorised in the appropriate category & aircraft type is capable of meeting this requirement. A list of such supervisors is contained on form ALT/QC/065, appendix 4 and as approval code T on the ALT/QC/10 Personal Authorisation Certificate. b/ The procedure is applicable when an engineer is applying for the addition of a first type rating in a particular subcategory as detailed in 66.A.45 (c). c/ OJT may only be performed where ALT holds the appropriate Part 145 type approvals as listed on the EASA Form 3 & further detailed in MOE 1.9. d/ During the day to day OJT performance, the supervisor should aim at overseeing the complete process including task performance, completion, use of manuals and procedures, observance of safety measures, warnings, recommendations and adequate behaviour in the maintenance environment. This should be done on a one-to-one basis. Supervisors should be available for consultation during task completion. A section for supervisor comments is available in the OJT record and forms part of the final assessment, therefore it should be completed. e/ Supervisors must be appropriately authorised on type, safety orientated, capable of coaching as well as being competent. Q1 & Q Page 14 of 26
15 6. Quality Notices Quality Memo s will be renamed as Quality notices. These are distributed as before and can be found on Techcom. A new procedure will be issued as TP45 and it is worth noting that once issued a read and sign register will need to be signed at the line station level and is the responsibility of the line mangers to ensure completed. This will then be part of the station audits. The following pages contain the latest Quality Notices for the period. Q1 & Q Page 15 of 26
16 Personal Tools Re-issue of Quality Memo QM/07/09/15 Issued 7 th September 15 Originally issued 12 th January 2016 as Quality Memo QM/12/01/16 A UK CAA audit in August 2015 highlighted issues with personal tools in regards to tool inventory lists and calibrated tooling which QM/07/09/15 was issued to inform all Engineering staff, however a further UK CAA audit was carried out on 7 th January 2016 and yet another finding was raised in regards to an Engineers personal tool kit containing an item that requires calibration and it was evident that it was not calibrated and not under the control of the ALT calibration system. EASA Part 145 Regulations 145.A.40 (b) Equipment, Tools and Material states: The organisation shall ensure that all tools, equipment and particularly test equipment, as appropriate, are controlled and calibrated according to an officially recognised standard at a frequency to ensure serviceability and accuracy. Records of such calibrations and traceability to the standard used shall be kept by the organisation. All Engineering staff are reminded to ensure that their personal tool kit does not include tooling that requires calibration, unless this is under the control of the ALT calibration system. Personal Tool Inventory List: During the audit in August 2015 a personal tool kit inventory list was checked and all tools were present, however a copy of this was not in the line station file as specified in MOE L2.8.1 as below: L2.8.1 Personal Tool Control. ALT engineers and mechanics will ensure that all personal tools are in good condition and securely stored when not in use, further more each tool will be clearly identified and listed on a Tool Inventory Sheet, and kept with the tools. The Tool Inventory Sheet must be amended each time there is a change in tool status. The tool inventory sheet can be of any style as long as the following information is recorded: 1) Name and Surname 2) ID used to identify personal tooling 3) All personal tooling is described and identified on the Inventory List. Q1 & Q Page 16 of 26
17 A copy of each person s Tool Inventory Sheet will be kept on file in the line station office for identification purposes. This list is to be replaced with a new copy each time the Tool Inventory Sheet is amended. The Line Maintenance Manager or the Line Station Engineer will conduct no less than two random checks per month to ensure that personal tooling is correctly controlled. The Quality Department will verify that the required monthly checks have been conducted and that copies of each person s tooling is available, and depending on the results of these checks, may carry out further checks. Items that are considered to be consumables like, but not limited to, drill bits, cutting disks, pipe blanks, skin pins ect, need not appear on the Tooling Inventory Sheet. Please ensure that an up to date copy of your personal tool inventory list is held in the appropriate line station file. Calibrated Tooling: During the audit in August 2015, a personal tool kit inventory list was checked and was found to have a fluke multimeter listed with no calibration evident and during the audit in January 2016 another personal tool kit inventory list was checked and was found to have a crimp tool listed with no calibration evident. On further investigation of both items, it was confirmed that the tooling was not under control of ALT calibration process as per MOE as below: Personal Instrument / Tool control It is not ALT policy to issue Engineers with their own personal tooling. Personally owned calibrated tooling may only be used if the item is under the ALT system for control and calibration. Please ensure that if you have tooling that requires calibration that it must be controlled by the ALT calibration system as per MOE 2.6.4, otherwise it must be removed from your toolbox and taken off station. Q1 & Q Page 17 of 26
18 Daily Check Sheets A Originally issued 1 March 2016 as Quality Memo QM/01/03/16 It has been highlighted during a recent EAT Compliance Monitoring Audit that ALT Engineers from various ALT Line Stations are signing off A (PW4000) Daily Checks in the Technical Logs IAW EAT Form 60. Please be aware that this form is for EAT Engineers only. ALT Engineers shall sign off the Daily Check in the Technical Log IAW EATL/ENG/XXXA/006/R05 as per the extract below from the Daily Check Form: Q1 & Q Page 18 of 26
19 Goods Inwards Inspection - TCAS Modification & A Check Auch Initially issued 14 March 2016 as Quality Memo QM/14/03/16 Please see below for guidance on Goods Inwards Inspection process for the TCAS MOD and A Check on 9H-AVM at JCB Aero, Auch: Goods In (External) Engineers automatically have Goods Inwards Inspection under PAC Authorisation code D. ALT has an approved Goods Inwards Inspector in Brussels. Principles All items ordered by the Operator must be: Inspected physically Be accompanied by appropriate acceptable documentation Have a batch number issued by ALT Have the documentation retained by ALT Quarantined/rejected if they are deficient in some way or the paperwork is not acceptable. Process Parts/Materials are shipped direct to site by the customer Engineers must inspect the parts versus the paperwork If unsatisfactory the item must not be used and returned to customer with reason for rejection. If satisfactory the paperwork is to be sent BRU, silviaterna@altitudeglobal.aero BRU Goods In will run a separate file for the particular job, book the item in, retain the paperwork and send a batch number back to the Engineers onsite. Parts can then be used with the relative batch numbers to be recorded on the Aircraft paperwork. Any aircraft parts or raw material issued by the hangar need to be accompanied by the same documentation as above and follow the same process. Paperwork 1) Raw material (sheet metal/solid fasteners) need to accompanied by a Mill Certificate (manufacturers Certificate of Conformity), traceable to the manufacturer showing the specification and any treatments applied. Q1 & Q Page 19 of 26
20 2) Sealants must be accompanied by Manufacturers C of C 3) Standard Parts must be accompanied by C of C (typically filaments, AN/MS/NAS parts, i.e. made to an international standard) 4) Anything else must have an EASA Form 1 for new or used, FAA Form 8130 if new or FAA 8130 with EASA dual release if used. Remember a Suppliers C of C alone is not acceptable. You must have traceability back to the manufacturer for items 1, 2 & 3. NOTE: Please see Appendix 1 to this QM for TP11 Paragraph 10 in regards to spares control for BRU (non-dhl) Line Station. Q1 & Q Page 20 of 26
21 7. Safety Notices ALT EASA Part 145 Continuation Training. Safety Memo s will be renamed as Safety Notices. These are distributed as before and can be found on Techcom. A new procedure will be issued as TP45 and it is worth noting that once issued a read and sign register will need to be signed at the line station level and is the responsibility of the line mangers to ensure completed. This will then be part of the station audits. The following pages contain the latest Quality Notices for the period. Q1 & Q Page 21 of 26
22 Inadvertent Escape Slide Deployment Originally issued as Safety Memo SM/03/02/16 This Safety Memo is issued to highlight a recent MEDA investigation into an inadvertent escape slide deployment. All Engineers are reminded that when entering/exiting an Aircraft, the AMM for that particular type must be adhered to with regard to arming/disarming the door. Prior to opening a door from the inside, ensure that the correct procedure for disarming has been carried out in accordance with the applicable AMM. On aircraft that have arrived, the doors must not be opened externally; you must wait until the crew opens the door before proceeding up the steps. For information, please see below a copy of the DHL Global Aviation Procedures & Standards Manual PART C, Aircraft Ground Handling Chapter: 1 Issue Nr: Issued January 2016 (GAPS procedure) for the opening of cabin doors: GAPS C Opening Of Cabin Doors 1. Opening aircraft doors Cabin Doors Aircraft doors must only be operated by the flight crew or by appropriately trained and qualified staff. When the flight crew are on-board i.e. on arrival, the cabin doors shall only be opened from the inside and after the appropriate signal has been given by the ground crew. The standard signal to be used is: Knocking on the door As soon as the signal has been given by the ground crew, the ground crew must immediately retreat to a safe distance on the stairs platform to avoid being struck by either the door or the escape slide in case of inadvertent activation (if applicable). Ground crew must remain well clear of the door until it has been fully opened. If a flight crew member is visible at the time of knocking, a thumbs up signal may be given. If the flight crew are unavailable at the time of knocking, the ground crew must immediately retreat after knocking and shall not approach the door again unless contact has been made with the crew to clarify the situation. For aircraft which do not have a window in the passenger door, the thumbs up signal may be given by a member of the loading team positioned at the head of the stand in full view of the flight crew. Q1 & Q Page 22 of 26
23 Once the door is fully open, the handrails of the stairs must be extended. In situations where a flight crew member is not on-board the aircraft, cabin access doors shall only be opened by authorised personnel and shall only be opened in accordance with the approved procedures. Under no circumstances shall the cabin door be opened if the stairs have not been positioned and the standard signal given by the ground crew. Similarly, the stairs must never be taken away from the aircraft until the crew have been notified and the door has been fully closed. If the cabin door is to be re-opened after it has been fully closed, approval must first be sought from the commander via headset or approved hand signals, then the door shall be re-opened using the approved process. Note: Positioning of the stairs must be fully in accordance with procedures outlined in GAPS C (Point 6) Positioning of Mobile or Towable Aircraft Steps. Main-deck cargo doors Main deck cargo doors must only be operated by the crew or ground staff that have been specifically trained and authorised for the function. Training must be specific to the type of aircraft and door being operated. Main-deck Cargo Door Safety Barrier Nets Safety Barrier Nets must always be installed whenever the cargo-door is open and no High-Loader is positioned at any Main-deck Cargo Door. Q1 & Q Page 23 of 26
24 Tech Note: 767-GEN L/E Slat Defect investigation Originally issued as Safety Memo SM/02/02/16 This is to provide you with feedback on an MOR report submitted back in April relating to a LE Slat defect on a B767 Aircraft, where No.8 and No.10 slats inboard target sensors were found crossed over with o/board target washers. Following receipt of a SARS report (2015/158) from an AGL Engineer, a request was sent to the Operator to submit to the authorities, investigate and provide feedback to us. The Operator confirmed that the MOR was submitted to the CAA in accordance with the recognised procedure. We subsequently received the following closure from the Operator: Summary: Post 'C' Check aircraft arrived with a LE SLAT defect. Slat moved OK on hydraulics but in alternateslats locked out at selection 1. FSEU BITE carried out with code LE SLAT asymmetry RH code PSEU BITE carried out with codes 302 and 304. Nr 8 and nr 10 slats inspected and inboard slat proximity detectors found missing. On deeper inspection (Ref IPC ) found inboard proximity detector target fitted to outboard slat proximity detector and outer fitted in inboard position. Targets swapped into correct positions for slats 8 and 10 (Ref IPC ) and functions c/o AMM all now satisfactory. Action: Engineering investigation determined that the inboard and outboard slat position sensor targets on the #8 and the #10 leading edge slats were transposed. The targets were removed and refitted in their correct locations. These slats were among those which had been removed from the aircraft during the 'C' Check at BHX and from here the aircraft was positioning at the time the incident occurred. Following rectification the aircraft underwent a check flight involving two take-offs and landings with no further reports and was returned to service. Subsequent investigation by the C check agency found that the sensor targets were transposed through human error. The team involved was not aware of B F Technical Note 767-Gen-027, which drew attention to Vulnerable Maintenance Tasks and cited this specific issue although the Technical Note was available to them. The MRO agency has taken appropriate remedial action. Company (Operator) Closure Recommendation: This report is recommended for closure by Engineering Management in view of the above action. The Reporter has received this feedback and it was suggested that it would be useful to circulate a notice to all engineers in order to highlight this potential hazard. Please see attached a copy of Technical Note 767-GEN-027, for your information. Q1 & Q Page 24 of 26
25 Door Operation observed not in line with the Standard Originally Issued as Safety Memo SM/09/02/16 issue 2 This Safety Memo is issued in response to a non conformance report (NCR) raised by EATL regarding Door Operation which has been observed as being carried out not in line with the standard. The NCR read as follows: Are cabin door operations safe and appropriate? Door Operation has been observed not in line with the standard. The L1 Door has been fully opened by AGL Engineer (Flying Spanner) from inside before stairs have been positioned. In addition to the recent publication (SM/03/02/16) issued as a result of an inadvertent slide deployment, this Safety Memo is specifically issued to ensure that all Engineers are fully conversant with the DHL Global Aviation Standard Operating Procedures and GAPS C relating to the Opening of Cabin Doors. All Engineers are reminded that when entering/exiting an Aircraft, the AMM for that particular type must be adhered to, along with DHL GAPS Procedures with regard to opening/closing the door as set out below: GAPS C Opening Of Cabin Doors 1. Opening aircraft doors Cabin Doors Aircraft doors must only be operated by the flight crew or by appropriately trained and qualified staff. When the flight crew is on-board i.e. on arrival, the cabin doors shall only be opened from the inside and after the appropriate signal has been given by the ground crew. The standard signal to be used is: Knocking on the door As soon as the signal has been given by the ground crew, the ground crew must immediately retreat to a safe distance on the stairs platform to avoid being struck by either the door or the escape slide in case of inadvertent activation (if applicable). Ground crew must remain well clear of the door until it has been fully opened. If a flight crew member is visible at the time of knocking, a thumbs up signal may be given. If the flight crew is unavailable at the time of knocking, the ground crew must immediately retreat after knocking and shall not approach the door again unless contact has been made with the crew to clarify the situation. For aircraft which do not have a window in the passenger door, the thumbs up signal may be given by a member of the loading team positioned at the head of the stand in full view of the flight crew. Once the door is fully open, the handrails of the stairs must be extended. Q1 & Q Page 25 of 26
26 In situations where a flight crew member is not on-board the aircraft, cabin access doors shall only be opened by authorised personnel and shall only be opened in accordance with the approved procedures. Under no circumstances shall the cabin door be opened if the stairs have not been positioned and the standard signal given by the ground crew. Similarly, the stairs must never be taken away from the aircraft until the crew has been notified and the door has been fully closed. If the cabin door is to be re-opened after it has been fully closed, approval must first be sought from the commander via headset or approved hand signals, then the door shall be re-opened using the approved process. Note: Positioning of the stairs must be fully in accordance with procedures outlined in GAPS C (Point 6) Positioning of Mobile or Towable Aircraft Steps. Main-deck cargo doors Main deck cargo doors must only be operated by the crew or ground staff that have been specifically trained and authorised for the function. Training must be specific to the type of aircraft and door being operated. Main-deck Cargo Door Safety Barrier Nets Safety Barrier Nets must always be installed whenever the cargo-door is open and no High-Loader is positioned at any Main-deck Cargo Door. Note: Please be aware that in respect of the penultimate paragraph of the Operator s procedure entitled Main-deck cargo doors, the stated requirement is acceptable to Altitude Global, as irrespective of how our engineers are classified; they are qualified, approved and certified for the necessary function. - END - Q1 & Q Page 26 of 26
CONTINUATION TRAINING
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