npa 2007-08amendment to part-m for aircraft not used in ：npa 2007-08amendment到第一部分- m不在飞机上的应用

NPA 2007-08Amendment to Part-M for aircraft not used in Commercial Air TransportJuan Anton21 June 2004 Czech RepublicDGINT/2European Aviation Safety AgencyCurrent requirementsOn 20 November 2003 the European Commission adopted Regulation (EC) 2042/2003, on the continuing airworthiness of aircraft and aeronautical products, parts and appliances, and on the approval of organisations and personnel involved in these tasks.This Regulation includes Implementing Rules (Part-M, 145, 66 and 147). In particular, Part-M introduces measures to be taken to ensure that airworthiness is maintained, included maintenance. 21 June 2004 2DGINT/2European Aviation Safety AgencyCurrent requirementsFor aircraft involved in Commercial Air Transport, most of the Part-M requirements have been mandatory since 28 September 2005.For aircraft not involved in Commercial Air Transport, Part-M requirements are not applicable yet (for countries that have opted-out), but its implementation can not be postponed further than 28 September 2008.21 June 2004 3DGINT/2European Aviation Safety AgencyPart-M Regulatory Impact Assessment and NPA 07/2005Article 7(6) of (EC) No 2042/2003 required the Agency to make an evaluation of the implications of the provisions of Part-M.Such evaluation was performed through NPA 07/2005, and the resulting CRD 07/2005 was published on April 30th, 2007. 21 June 2004 4DGINT/2European Aviation Safety AgencyFurther changes to those proposed by NPA 07/2005Since Industry and NAAs had requested further changes to Part-M (in addition to those from NPA 07/2005) in order to alleviate the requirements imposed in non-commercial air transport operations, especially on light aircraft, and since it was necessary to develop Acceptable Means of Compliance (AMCs) and Guidance Material, the Agency created Working Group M.017. This group was also tasked to evaluate the comments received through NPA 07/2005 and to develop CRD 07/2005, as well as to evaluate maintenance related comments received from MDM.032 “A better concept for General Aviation”.21 June 2004 5DGINT/2European Aviation Safety AgencyFurther changes to those proposed by NPA 07/2005In addition to Working Group M.017, Working Group M.005 was also created in order to address the issue of “Pilot Owner Maintenance” and to produce a revised Appendix VIII that would better adapt the needs of non-complex aircraft not involved in commercial air transport. The concept of “jointly owning” an aircraft has also been addressed.THE RESULT OF THE WORK PERFORMED BY M.017 AND M.005 IS THE NPA 2007-08 THAT HAS BEEN PUBLISHED AT THE END OF JUNE 2007.21 June 2004 6DGINT/2European Aviation Safety AgencyFurther changes to those proposed by NPA 07/2005During the work performed by Working Groups M.017 and MDM.032, it was found necessary to study the possibility of creating an aircraft maintenance licence specific for light aircraft, the so-called “B3 aircraft maintenance licence“.This task (called 66.022) has been undertaken by a sub-group of M.017 and is currently under discussion.21 June 2004 7DGINT/2European Aviation Safety AgencyEnvisaged calendarNPA 2007-08 has been published on 25 June 2007.The comment period for CRD 07/2005 finished on 26 June 2007.However, since some of the changes introduced have been further developed by NPA 2007-08 (ARC issuance conditions, Pilot Owner Maintenance.), it is the intention of the Agency not to publish an Opinion following CRD 07/2005, and publish a single Opinion by the 1st quarter 2008 covering both CRD 07/2005 and NPA 2007-08.Consultation for NPA 2007-08 finishes by on 13 October 2007.CRD expected to be published by December 2007, ending the consultation period by February 2008.Opinion (for CRD 07/2005 and NPA 2007-08) by March 2008.Approval by the Commission hoped before June 2008, with Decision on AMC and Guidance Material adopted immediately.21 June 2004 8DGINT/2European Aviation Safety AgencyTransitional measuresIn view of the envisaged schedule: Organisations will likely withhold their application for M.A. Subpart F, Subpart G and Subpart I approval until the envisaged changes are approved by the Commission. Competent Authorities will probably not be able to complete the corresponding investigations and issue the approval certificates before 28 September 2008. There will be a need to consider some transitional arrangements which may include:Q Possible grandfathering measure to facilitate issuing of approvals to organisations already performing similar tasks under national regulations, and/orQ Postponing the entry into force of those provisions that can not be reasonably implemented before 28 September 2008. Such arrangements can not be elaborated until there is a better view of the implementation difficulties.21 June 2004 9DGINT/2European Aviation Safety AgencyTransitional measuresAs a consequence, the Agency has strongly encouraged the Competent Authorities not to introduce provisions in their national regulations that force the organisations to comply with current Part-M requirements that are very likely to be amended.This is further supported by the fact that both CRD 07/2005 and NPA 2007-08 envisage the removal of the “12 month in a controlled environment” requirement before a CAMO can issue an ARC (after a full airworthiness review).21 June 2004 10DGINT/2European Aviation Safety AgencyTransitional measuresIt is not the intention of EASA to propose postponing the entry into force of the whole Part-M as a block as it is likely that more proportionate measures may be a better way to address the necessary transition from the national systems to Part M;Such measures may include a phased introduction of particular provisions of Part-M, based on supporting evidence from the analysis of the comments received during the consultation of NPA 2007-08;They may also include grand-fathering provisions such as the grant of Part M Subpart F (maintenance organisation) and/or Subpart G (CAMO) and/or Subpart I (ARC privileges) approvals to all organisations that have been granted a similar approval under national rules, subject to some transitional conditions (see the precedents in Regulations 1702/2003 and 2042/2003).21 June 2004 11DGINT/2European Aviation Safety AgencyTransitional measuresWe therefore encourage regulated persons and competent authorities to provide comments in relation to the particular areas that may pose an implementation problem, together with substantiation and proposals.In order to accelerate the process, the Agency will review all comments received as soon as possible, so the areas requiring appropriate transitioning can be identified before the end of 2007.We will also examine with National Aviation Authorities the possibility to incorporate under national regulations provisions of Part-M, Subparts F, G and I, together with the changes proposed by NPA 2007-08, permitting voluntary organisations to start the transition process without waiting for publication of the amended regulation in the official journal.21 June 2004 12DGINT/2European Aviation Safety AgencyNPA/CRD 07/2005NPA2007-08 (related to M.017)Changes introduced in: NPA/CRD 07/2005, andNPA 2007-08 (related to M.017)21 June 2004 13DGINT/2European Aviation Safety AgencyRevision of Part-M versus “Light Part-M”Feedback from Industry showed a preference for a separate “Light Part-M”.However, EASA did not find enough justification in doing so because of the following reasons: Most of the paragraphs of the current Part-M remain unchanged. There is no need for duplication. This duplication would have meant more inconsistencies and duplicated work when keeping both documents updated (including approval from the Commission). Owners/operators trying to move from non commercial air transport to commercial air transport would have needed to learn two separate regulations, trying to identify the differences between each other. This difference is much more evident having a single regulation with some articles split in commercial and non-commercial air transport (with an appropriate weight limit).21 June 2004 14DGINT/2European Aviation Safety AgencyChanges not adopted (FAA AC 43-13) Acceptance of FAA AC 43-13: AC 43-13 states that its material can only be used for minor repairs (no major repairs). However, the decision (minor / major) has to be adopted by a Part-21 design organisation (the outcome of MDM.032 may facilitate it) As a consequence, currently there is no legal basis to accept the proposal. A rulemaking task is going to start in 2008 to develop and approve a document similar to AC 43-13.21 June 2004 15DGINT/2European Aviation Safety AgencyChanges not adopted (FAA 8130-3 issued by non-Part-145 Repair Stations)Acceptance of FAA 8130-3 issued by FAA Repair Stations not approved in accordance with Part-145: Components maintained prior to 28 September 2008 may be issued a Form 1 (under the conditions of AMC M.A.613(a). Components maintained afterwards are not acceptable (not allowed by the corresponding bilateral agreements). The following considerations may reduce the impact:Q Reduce the number of components requiring a Form 1 or equivalent, and also allow the owner to fabricate certain non critical parts (under study by MDM.032).Q Such maintenance may also be performed by Part-145 organisations (which in many cases already exist).Q FAA repair stations may see a business case with the new General Aviation market and get the Part-145 approval. It is fairly easy and inexpensive (bilateral agreement)21 June 2004 16DGINT/2European Aviation Safety AgencyWhat is a “competent authority“New AMC M.1:A competent authority may be a ministry, an aviation national authority or any aviation body designated by the Member State.A Member State may designate more than one competent authority to cover different areas of responsibility (no overlap of responsibilities).21 June 2004 17DGINT/2European Aviation Safety Agency“Indirect Approval Procedure“ of maintenance programmesCurrent Rule M.A.302(e):The maintenance programme and its amendments may be approved through an “indirect approval procedure“ established by the CAMO responsible for the management of the aircraft.CRD 07/2005 clarifies what is an “indirect approval procedure“ (M.A.302(b):It is a procedure established by the CAMO, included in the exposition and approved by the competent authority (the one responsible for the oversight of the CAMO.In this case, the maintenance programme and its amendments are formally approved by the CAMO (no need for competent authority endorsement).21 June 2004 18DGINT/2European Aviation Safety Agency“Indirect Approval Procedure“ of maintenance programmesNPA 2007-08 addresses the case where the State of Registry is not the State responsible for the oversight of the CAMO. (M.1 and M.A.302(b):Usually, the Member State of Registry is responsible for the approval of Maintenance Programmes.The “indirect approval procedure“ is a procedure approved by the competent authority responsible for the CAMO.If they are different Member States, the responsibility falls on the State of Registry, unless there is an agreement between both countries. If there is no agreement, the “indirect approval procedure“ can not be used on that particular aircraft.21 June 2004 19DGINT/2European Aviation Safety AgencyMaintenance programmes not linked to an operator (independent CAMOs)NPA 2007-08 introduces in M.A.302(c) the concept of BASELINE and GENERIC maintenance programmes:Purpose: permit the approval of the CAMO without having any customer.Only for aircraft not involved in Commercial Air Transport.Based on the maintenance programme recommended by the TC holder.“Baseline“: for a particular aircraft type.“Generic“: to cover several similar aircraft types.21 June 2004 20DGINT/2European Aviation Safety AgencyMaintenance programmes not linked to an operator (independent CAMOs)AMC M.A.302 revised to include:UK-LAMS is an example of “Generic“ maintenance programme.“Baseline“ and/or “generic“ maintenance programmes are not applicable to a particular “registration mark“.Should be available to the competent authority prior to the CAMO approval and will be listed in Form 14.After the approval of the CAMO, these programmes shall be revised to include specific tasks for each customer (for each registration mark).May be revised through the “indirect approval procedure“.21 June 2004 21DGINT/2European Aviation Safety AgencyReliability ProgrammesCRD 07/2005 clarifies in M.A.302(e) that a Reliability Programme is not required for other than large aircraft.21 June 2004 22DGINT/2European Aviation Safety AgencyOperators Technical LogCRD 07/2005 clarifies in M.A.305(b) that the Operators Technical Log is only required for Commercial Air Transport and when required by the Member State in accordance with M.A.201(i).21 June 2004 23DGINT/2European Aviation Safety AgencyWhat is a work card / worksheetCurrent Rule M.A.401(c):The person or organisation maintaining an aircraft shall establish a work card or worksheet system to be used and shall either transcribe accurately the maintenance data onto such work cards or worksheets or make precise reference to the particular maintenance task or tasks contained in such maintenance data.NPA 2007-08 amends AMC M.A.401(c):For aircraft 2730 Kg MTOM and below these systems may take the form of: A format where the mechanic writes the defect, action and maintenance data used, An aircraft log book with the defect, action and maintenance data used, For maintenance checks, the checklist issued by the manufacturer (i.e. 100h checklist).21 June 2004 24DGINT/2European Aviation Safety AgencyComponent maintenanceNPA 2007-08 modifies M.A.502(b) and introduces new AMC M.A.502 and AMC M.A.502(b) to clarify the following: Component removal and installation from an aircraft is not considered component maintenance, but aircraft maintenance. The normal requirement is that component maintenance must be performed by approved organisations (C rated organisations). Nevertheless, component maintenance may be performed by independent certifying staff or A rated organisations when:Q Maintenance in the component is performed in accordance with aircraft maintenance data, andQ The component stays installed on the aircraft, or the aircraft maintenance data describes or permits the removal of such component.In this case, the component can not be released with a Form 1, but in accordance with the aircraft release procedures.21 June 2004 25DGINT/2European Aviation Safety AgencyControl of unserviceable componentsCurrent Rule M.A.504(b) and AMC material:Unserviceable components shall be identified and stored in a secure location under the control of the M.A.502 approved maintenance organisation until a decision is made on the future status of the component.M.A.801(b)(2) certifying staff performing aircraft maintenance should send, with the agreement of the aircraft owner/lessee, any unserviceable component to an approve maintenance organisation for controlled storage.NPA 2007-08 amends AMC M.A.504(b) to clarify that:A secure location may be any location described in the procedures of the approved maintenance organisation for which the organisation is responsible, and may include locations away from the main maintenance facilities.The purpose is to facilitate access to those locations to the M.A.801(b)(2) certifying staff removing the component.21 June 2004 26DGINT/2European Aviation Safety AgencyRequirements for continued experience of certifying staffFor certifying staff in Subpart F maintenance organisations, the 6 months experience requirement in every 2 years period has been changed to refer to the experience requirements of Part-66, which in the case of sailplanes and balloons refer to national rules.This change also aligns with the requirement of M.A.801(b)(2) that requires independent certifying staff to be in compliance with the requirements of Part-66.21 June 2004 27DGINT/2European Aviation Safety AgencyWhat is a work orderCurrent Rule M.A.610:Before the commencement of maintenance a written work order shall be agreed between the organisation and the customer to clearly establish the maintenance to be carried out.M.A.610 has been revised in CRD 07/2005 to replace “customer“ by “the organisation requesting maintenance“. “Organisation“ includes natural persons.A new AMC M.A.610 ha