Volume 12 international aviation
CHAPTER 8 evaluate an EASA supplement to a repair station manual/quality
Section 1 Background and Procedure
12-524 PROGRAM TRACKING AND REPORTING
SUBSYSTEM (PTRS) ACTIVITY CODES.
A. Maintenance: 3377, 3669, 3771.
B. Avionics: 5377, 5669, 5771.
12-525 OBJECTIVE. This chapter
provides guidance for evaluating the European Aviation Safety Agency (EASA)
supplement to a repair station manual/quality control manual (RSM/QCM). See
Volume 2, Chapter 11, Section 6, Process the Application of a Domestic Repair
Station for Approval Under European Aviation Safety Agency Part
145, for the background and history of EASA.
A. Before a repair station may
be approved by EASA under EASA Part-145, the repair station must prepare an
EASA supplement to its RSM/QCM. The Federal Aviation Administration (FAA) will
review and accept the initial supplement on behalf of EASA. If the repair station
revises the supplement it should submit the revisions to the FAA. Revisions
to the supplement are considered accepted by the FAA unless the repair station
is notified otherwise by FAA.
B. If this task is performed
as part of processing an original application for EASA Part-145 approval, the
entire EASA supplement will be submitted. If this task is performed as part
of processing a continuation approval, or conducting a review of a revision
to the EASA supplement, only the revised portion of the EASA supplement will
C. The information contained
in the EASA supplement is based on EASA Part-145, special conditions contained
in the Maintenance Implementation Procedures (MIP) of a Bilateral Aviation Safety
Agreement (BASA). These special conditions state that the repair station must
provide a supplement to the RSM/QCM accepted by the FAA on behalf of EASA to
include policy and procedures for the following:
1) Cover page.
2) List of Effective Pages.
3) Amendment procedures.
5) Accountable Manager’s Commitment
Statement. This is a statement by the accountable manager, as defined by EASA
Part-145, that commits the repair station to the EASA special conditions.
6) Approval Basis and Limitation. This
complies with its FAA rating and operations specifications (OpSpecs).
7) Access by EASA and FAA.
8) Work Orders/Contracts. These include
procedures to ensure completeness of and compliance with the customer or operator
work order or contract including any supplied EASA airworthiness directives
(AD) and other notified mandatory instructions.
9) Approved Design Engineering Data.
This includes procedures to ensure repairs and modifications, as defined by
EASA requirements, are accomplished in accordance with (inspected in accordance
with) EASA-approved data.
NOTE: Automatically approved data and data which
requires formal approval (critical components) and limitations regarding acceptable
minor repair design data is repair design data developed by U.S. organizations/persons
for use on EU-Registered aircraft and related articles. This data may be used
under certain circumstances (reference appendix 1 to EASA MIP Guidance Example
Supplement paragraph 8, Approved Design Engineering Data).
10) Airworthiness Directives. This should
include procedures to ensure EASA ADs are used when provided by the customer.
11) Major Repairs/Alterations/Modifications.
This includes procedures to ensure completeness of and compliance with the customer
or operator work order or contract, including any supplied EASA ADs and other
notified mandatory instructions. The procedures should ensure that the operator/customer
has obtained EASA approval of the data used.
12) Release of Components After Maintenance.
Ensure use of FAA Form 8130-3, Airworthiness Approval Tag, for aircraft components,
and any other information required by the owner or operator, as appropriate.
13) Certificate of Airworthiness (C
of A) Validity. For a repair station rated for an aircraft type, procedures
to ensure that the aircraft’s airworthiness review certificate has not expired
before releasing or returning the aircraft to service. The airworthiness review
certificate is located behind the airworthiness certificate.
14) Release of Aircraft After Maintenance.
Procedures for the release or approval for return to service that meet the requirements
of EASA Part-145, § 145.50 for aircraft.
15) Reporting of Unairworthy Conditions.
Procedures for reporting to EASA, aircraft design organizations, and the customer
or operator unairworthy conditions on civil aeronautical products as required
by EASA Part-145.
16) Quality Monitoring System (QMS).
Detailed procedures for operating an independent QMS.
17) Provision of Hangar Space for Aircraft
18) Contracted Maintenance. The repair
station must specify the items to be contracted and have procedures in place
to ensure contractors meet the terms of the implementation procedures (that
is, using an EASA-approved source), or work under the repair station’s contracted
provisions of Title 14 of the Code of Federal Regulations
(14 CFR) part 145.
19) Human Factors. How personnel are
trained to ensure an understanding of the application of human factors principles.
20) Air Carrier Line Stations. Line
stations located in the United States as part of a CFR part
121 air carrier can only be accepted if that air carrier holds
a CFR part
145 repair station certificate. The EASA Supplement to the RSM must include
a procedure that clearly demonstrates that the quality system covers all stated
activities. All line stations associated with EASA Part-145 approval need to
be listed in the EASA Supplement together with associated aircraft type and
primary maintenance capability. Line stations located in the European Union
member states are not accepted under this process.
21) Work Away from a Fixed Location.
A repair station may perform work away from its fixed location for a one time
special circumstance if the EASA Supplement does not have written procedures
for work away from the station. On a reoccurring basis when necessary subject
to the FAA OpSpecs D100 being in place for this work and only to perform emergency
or non-routine maintenance.
22) A procedure for providing the FAA
with a copy of its EASA approval certificate and a copy of the EASA letter of
continuation approval, as appropriate. (This should occur each time a continuation
approval letter is received.)
D. Specific EASA guidance for
preparing an EASA supplement to an RSM is contained in European Aviation Safety
Agency Guidance Material for the U.S./European Bilateral Aviation Safety Agreement
(BASA) and Maintenance Implementation Procedures Guidance (MIP), referred to
as MIP-G. The MIP-G also contains a sample EASA supplement. This document is
provided to a repair station in response to a preliminary inquiry regarding
initial EASA Part-145 approval. It should be reviewed thoroughly by the inspector
and used in conjunction with this chapter in conducting a review of an applicant’s
EASA supplement. MIP-G may be obtained from the EASA Web site
12-527 PREREQUISITES AND COORDINATION
Knowledge of the regulatory requirements of 14 CFR parts
Knowledge of the requirements of
volume 2, chapter 11, section 6 and EASA MIP-G;
Successful completion of the Airworthiness Inspector Indoctrination course or
Successful completion of the foreign and domestic repair station training course
Previous experience with certification or surveillance of
14 CFR part 145 repair stations.
B. Coordination. This task requires
The applicant (repair station),
The applicant’s principal maintenance inspector (PMI) or principal avionics
The FAA regional EASA coordinator, and
FAA regional and district offices, as appropriate.
12-528 REFERENCES, FORMS, AND JOB
A. References (current editions):
Title 14 CFR parts
FAA Order 8130-21, Procedures for Completion and Use of the Authorized Release
Certificate, FAA Form 8130-3, Airworthiness Approval Tag,
Volume 2, Chapter 11, Introduction to Part
145 Repair Stations,
Chapter 6, Section 1, Support a Maintenance International Standardizaiton Team
EASA MIP-G, and
(AC) 145-5, Repair Station Internal Evaluation Programs.
FAA Form 8000-4, Air Agency Certificate,
FAA Form 8000-4-1, Repair Station Operations Specifications,
FAA Form 8130-3, Airworthiness Approval Tag,
EASA Form 9, FAA Status Report on EASA Approved
14 CFR Part 145 Repair Station or Application for EASA Approval, and
EASA Form 16, European Aviation Safety Agency, U.S.A. Repair Station Application
for Initial/Continuation/Amendment of EASA Part-145 Approval inspected in accordance
with the FAA/EASA MIP Agreement.
C. Job Aids. To be determined
A. Receive the Applicant’s EASA Part-145
1) For an initial application for approval,
ensure that the submission includes at least two copies of the EASA supplement
and that the EASA supplement is signed by the applicant’s accountable manager.
2) For a continuation or amendment of
approval requiring a revision of the EASA supplement or for any revision to
the EASA supplement, ensure the submission includes at least two copies of any
revision to the EASA supplement. (One copy is to be retained by the Flight Standards
District Office (FSDO), and the second copy is to be returned to the repair
station to identify any correction or change requirements the inspector has
B. Review the Applicant’s EASA Supplement/Supplement
Revision. The EASA supplement/supplement revision must be added to the applicant’s
14 CFR part 145 RSM/QCM. The EASA supplement must conform to the organizational
structure specified in the sample EASA supplement. If a section of the applicant’s
RSM/QCM addresses information required in the EASA supplement, the EASA supplement
may reference that section of the RSM/QCM by identifying the section, chapter,
and page that address the specific area, and including a brief summary. Review
the EASA supplement to determine whether it includes the following sections
and appropriate information.
NOTE: An inspector is not required to review an
applicant’s entire EASA supplement if the applicant is only submitting a revision.
1) List of Effective Pages. Verify that
the EASA supplement includes a list of the sections it contains, the page number
of each section, and the current revision date of each section. The revision
level and date should be indicated on each page.
2) Amendment Procedure. Verify that
this section describes the procedures the applicant will use to guarantee that
its EASA supplement remains current. Ensure the EASA supplement identifies,
by title, the person responsible for amending the EASA supplement and states
that the applicant will provide copies of any revision to its EASA supplement
to the FAA before implementation.
3) Introduction. Confirm whether this
section addresses the purpose of the EASA supplement. It must indicate that
work performed by the applicant is accepted by EASA through compliance with
the provisions of a BASA. This section also must indicate that the EASA supplement
addresses additional EASA requirements that the applicant must comply with to
retain EASA Part-145 approval.
4) Accountable Manager’s Commitment
Statement. Determine if a statement indicating that the applicant will comply
with the provisions of the EASA supplement and that is signed by the applicant’s
accountable manager for and on behalf of the applicant is included. This section
should also recognize the consequences of failing to meet applicable requirements
or standards. The accountable manager is the person who has corporate authority
for ensuring that all maintenance required by an aircraft operator can be financed
and performed to the standards required by EASA Part-145. The difference between
14 CFR part 145 and EASA Part-145 accountable manager is that the EASA accountable
manager is usually the applicant’s chief executive officer or president but
also may be the vice president of engineering in an organization where this
person sits on the organization’s corporate board and has full financial authority.
Whenever the accountable manager is replaced, ensure that the statement is signed
by the new accountable manager. An acceptable accountable manager’s commitment
statement is provided below:
a) This supplement, in conjunction with
the repair station’s accepted RSM/QCM defines the organization and procedures
on which EASA approval is based.
b) These procedures are approved by
the undersigned and must be followed, as applicable, when performing maintenance,
preventive maintenance, or alterations that are subject to EASA approval.
c) The repair station’s procedures do
not override the necessity of complying with any additional requirements formally
published by EASA and agreed to by the FAA.
d) I understand that EASA will issue
an approval, and list the repair station as an approved source of maintenance
for the European Community and EASA-associated countries in a formal EASA publication
while EASA is satisfied that the procedures are being followed and work standards
are being maintained. I understand that EASA reserves the right to revoke the
approval certificate and remove the repair station from the formal EASA publication
if EASA considers that procedures are not followed or standards are not upheld.
5) Approval Basis and Limitation. Verify
if this section indicates that EASA approval is based on the applicant’s compliance
with 14 CFR parts 43 and 145, and the EASA special conditions identified in
the MIP and described in MIP-G. Ensure that this section indicates that the
scope of work the applicant may perform is limited to the scope of work detailed
14 CFR part 145 certificate and that such work may be performed at the location
specified on its certificate and FAA OpSpecs/RSM/QCM. An EASA approval may not
be exercised outside the United States unless specifically authorized by EASA.
6) Access by the EASA and FAA. Verify
whether this section states that the applicant must agree to allow EASA, or
FAA staff acting on behalf of EASA, access to the repair station to check compliance
with procedures and standards and to investigate any problems.
7) Work Orders/Contracts. Determine
if this section establishes procedures that the applicant will use to ensure
that it obtains a clear work order from the customer specifying the work to
be completed. Verify that work orders specify the inspections, repairs, alterations,
overhauls, ADs, and parts replacements that should be accomplished. Also confirm
that this section lists a person, by title, responsible for communicating with
the customer in the case of any ambiguity in the work order. The customer ultimately
remains responsible for correctly informing the repair station, in a work order,
of all required maintenance and alterations it wishes to have performed to comply
with EASA Part-145 requirements.
8) Approved Design Engineering Data.
Ensure that this section establishes procedures the applicant will use to confirm
that the customer has provided data approved by EASA of either the type certificate
(TC) holder (or equivalent) or the customer, before performing work on a product.
NOTE: The section also should emphasize that data
developed under Special Federal Aviation Regulation (SFAR) 36, by a designated
engineering representative or through a special process approval, may not be
accepted automatically by EASA. Therefore, this section must describe the applicant’s
procedures for obtaining data approved by EASA.
9) Airworthiness Directives (AD). Ensure
this section describes the procedures the applicant will use to verify that
it holds a copy of all the EASA ADs when the applicant is performing work for
the customer. This section may note that the applicant may require the customer
to supply the EASA ADs the customer wishes the repair station to comply with.
10) Major Repairs, Alterations, or Modifications.
Ensure this section describes the procedures the applicant will use when performing
major repairs, alterations, or modifications to ensure the customer has either
obtained EASA approval for the repair or alteration data or confirmed that FAA
data is acceptable to EASA.
11) Release of Components After Maintenance.
Ensure this section describes the procedures the applicant will use to ensure
the release of components, up to and including complete powerplants, is performed
inspected in accordance with 14 CFR and paragraphs 7 through 12 of the applicant’s
EASA supplement. This section must state that, when the maintenance is complete,
FAA Form 8130-3 must be issued as a maintenance release by the applicant indicating
that the maintenance was performed inspected in accordance with 14 CFR parts
145 and EASA requirements.
a) Release to service of components
up to and including complete powerplants must be carried out in accordance with
43.9 and/or §
43.11, except that paragraphs 7 to 12 of this EASA supplement must also
be taken into account. At the completion of maintenance, FAA Form 8130-3 will
be issued as a maintenance release by the repair station.
b) The FAA Form 8130-3 should be issued
as a dual release as specified in FAA Order 8130-21 and should include the EASA
Part-145 release to service certifying statement with the EASA Part-145 approval
certificate number in block 13, and specify any overhaul, repairs, alterations,
ADs, replacement parts, or Parts Manufacturing Approval (PMA) parts and quote
the reference and issue/revision of the approved data used.
NOTE: EASA will not accept parts rebuilt under a
manufacturing certificate. A rebuilt part destined for Europe must be returned
to service inspected in accordance with FAA Order
c) An example completed Form 8130-3
must be included by the repair station in the EASA supplement. Instructions
should be included in the supplement specifying that blocks 14 through 18 are
not to be used by the repair station and that “newly overhauled” components
should be signed off in block 20 against the block 19 maintenance releases.
Block 19 must have both regulatory requirements blocks checked for a valid dual
d) The signature of the person returning
the component to service will be in block 20. The FAA repair station certificate
number should be in block 21.
e) The status of the component (repaired,
inspected, overhauled, etc.) will appear in block 12 with any relevant comments,
including detailed references to approved data, ADs, etc., in block 13. For
example: “Overhauled in accordance with CMM 111, section X, Rev 2, S/B 23 &
FAA AD xyz complied with. Full details held on WO 456.”
f) Block 13 shall also contain the following
statement: “Certifies that the work specified in block 12/13 was carried out
in accordance with EASA Part-145 and in respect to that work the component is
considered ready for release to service under EASA Part-145 Approval Number:
NOTE: The EASA BASA/MIP procedure only recognizes
the dual release FAA Form 8130-3 for component maintenance release.
12) Authorized Persons. The repair station
will retain and keep current a roster that identifies the list of persons authorized
to issue FAA Form 8130-3 on behalf of the repair station.
13) Incoming Inspection Procedures.
The EASA supplement’s incoming inspection procedures should include information
regarding the acceptability of components authorized for use during maintenance.
The following may be referenced to the RSM/QCM by section, chapter, and page
if these items are included as part of an incoming inspection procedure and
meet the intent of the following:
a) FAA allows the following to be referenced
in the RSM/QCM only to avoid duplication if the incoming system is the same.
means any component part of an aircraft, up to and including a complete powerplant
and any operational or emergency equipment.
2. Only the
following new and used components may be fitted during maintenance.
3. New components.
i. New components
should be traceable to the original equipment manufacturer (OEM) as specified
in the TC holder’s parts catalog and be in a satisfactory condition for installation.
The new component should be accompanied by a release document issued by the
OEM or Production Certificate (PC) holder. The release document should clearly
state that it is issued under the approval of the relevant National Aviation
Authority under whose regulatory control the OEM or PC holder works.
ii. For U.S. OEMs
and PC holders, release should be on the FAA Form 8130-3 as a new part.
iii. For all European
Union (EU) states, OEMs, and PC holders, release should be inspected in accordance
with EASA part 21.
iv. For Canadian
OEMs and PC holders, release should be on the Canadian form; Form One, Authorized
Release Certificate, as a new part.
NOTE: This form can be found on the Transport Canada
Civil Aviation (TCCA) Web page: http://www.tc.gc.ca/civilaviation/maintenance/RegsDocs/download.htm.
v. Standard parts
are exempt from the forgoing provisions, except that such parts should be accompanied
by a conformity statement, and be in a satisfactory condition for installation.
vi. PMA parts may
only be accepted as detailed in EASA part
21 or any EU/U.S. bilateral agreement.
4. Used components.
i. Used components
should be traceable to maintenance organizations and repair stations approved
by the authority that certified the previous maintenance, and/or in the case
of life-limited parts, certify the total service life. The used component should
be in a satisfactory condition for installation and be eligible for installation
as stated in the TC holder’s parts catalog.
ii. Used components
from EASA-approved U.S. repair stations should be accompanied by an FAA Form
8130-3 issued as a maintenance release.
iii. Used components
from a U.S. repair station that are not EASA-approved should not be used even
if accompanied by an FAA Form 8130-3 (a dual release would be needed to be accepted
iv. Used components
from EASA Part-145 approved maintenance organizations should be accompanied
by an EASA Form 1, Authorized Release Certificate, issued as a maintenance release.
NOTE: Components with only an EASA Part-145 return
to service should be segregated and identified as not for use on U.S.-registered
aircraft because they do not meet part
14) Certificate of Airworthiness Validity.
If the applicant has an airframe or limited airframe rating authorizing them
to perform work on an entire aircraft, verify whether this section describes
the procedures the applicant will use to ensure that the aircraft’s certificate
of airworthiness is valid.
a) The following subparagraph 14b is
only applicable to repair stations with airframe/aircraft and/or limited airframe
b) While EU aircraft have indefinite
certificates of airworthiness, their validity period is verified by an airworthiness
review certificate (ARC). The EASA operator or owner is responsible for ensuring
the certificate of airworthiness remains valid, but the repair station should
ensure that the certificate of airworthiness is valid from the expiration date
as detailed on the ARC before issuing a release to service as specified in subparagraph
15B below. If the ARC has expired, the customer should be informed before issue
of a release to service as specified in subparagraph 15B below.
15) Release of Aircraft After Maintenance.
If the applicant has an airframe or limited airframe rating, verify that this
section of the RSM/QCM describes the procedures the applicant will use to ensure
the release of aircraft is accomplished inspected in accordance with 14 CFR
and paragraphs 7 through 10 and 12 of the EASA supplement. Verify whether this
section indicates that when maintenance is complete, the applicant writes a
statement in the aircraft maintenance record that certifies that, except as
otherwise specified, the work was performed inspected in accordance with 14
CFR and, with respect to that work, the aircraft is considered ready for release
a) Ensure that this section notes the
use of the clause “except as otherwise specified” is intended for use with two
types of deviations, those in which:
1. All required
maintenance was not carried out. The maintenance not carried out must be listed
on the part 43, §
43.9 return to service and/or §
2. The particular
maintenance requirement was only EASA-approved and not FAA-approved. For example,
an EASA AD not approved by the FAA.
b) Ensure this section states that where
the customer or operator requires his/her paperwork to be signed, the following
alternate release to service certification can be made inspected in accordance
with EASA § 145.50: “Certifies that the work specified, except as otherwise
specified, was carried out in accordance with EASA Part-145, and in respect
to that work the aircraft is considered ready for release to service.”
c) In all cases the repair station must
issue the certification when all required maintenance has been carried out.
However, if it was not possible to complete all maintenance then such details
must be endorsed on the release to service and the operator informed.
d) The EASA Part-145 approval certificate
number and the
14 CFR part 145 certificate number must be quoted in all cases, whether
it is a part
43 return to service or an EASA Part-145 release to service.
NOTE: This subparagraph 15B is only applicable to
repair stations with airframe and/or limited airframe rating.
16) Reporting of Unairworthy Conditions.
Ensure this section describes the procedures the applicant will use to report
a serious defect found in EU-regulated aircraft or aircraft components. Ensure
this section indicates that the defect must be reported to EASA using
FAA Form 8070-1, Service Difficulty Report, or other means, and to the customer
within 3 days (72 hours) of discovery. When reporting a defect to EASA, the
identity of the customer must be included to allow for followup action.
17) QMS. The primary objective of the
QMS is to enable the organization to satisfy itself that it can deliver a safe
product and that it remains in compliance with
14 CFR part 43,
14 CFR part 145, and the EASA special conditions. There are two elements
to the system: an independent audit system and a management control and followup
a) Independent Audit System. The independent
audit system is a process of sample audits of all aspects of the repair station’s
ability to carry out all maintenance to the required standards. It represents
an overview of the complete maintenance system and does not replace the need
for mechanics to ensure that they carry out maintenance to the required standard,
nor does it replace any associated inspection/quality control system. Independence
should be established by ensuring that the personnel responsible for the function,
procedure, or product being audited do not carry out audits. The audit system
should cover the following:
Audits. The audits will monitor compliance with required aircraft/aircraft component
standards and adequacy of the maintenance procedures to ensure that such procedures
invoke good maintenance practices and airworthy aircraft/aircraft components.
Audits. The sample check of a product means to witness any relevant testing
and visually inspect the product and associated documentation. The sample check
should not involve repeat disassembly or testing unless the sample check identifies
findings requiring such action.
i. It is acceptable
to use personnel from one section/department to audit the work and products
of another section/department inspected in accordance with a procedure under
this subparagraph 17b, which defines the audit program.
ii. The process of
sample audits may be carried out once per year as a single exercise or subdivided
over a year period inspected in accordance with an audit program. All applicable
14 CFR part 43 and
145 paragraphs and the EASA special conditions as detailed in the EASA/FAA
MIP should be checked at least once per year against each primary product line.
iii. Repair stations
with fewer than 10 people may contract the audit function to a person acceptable
to EASA who is not employed by the repair station. However, in this case the
audit of all applicable
14 CFR part 43 and
145 paragraphs and EASA special conditions as detailed in the EASA/FAA MIP
must be carried out twice per year.
iv. A primary product
line is any one aircraft or engine or avionic or mechanical product line in
which the systems and procedures are very similar throughout that product line.
b) Management Control Followup System.
The management control followup system, which must not be contracted to outside
persons, consists of a system to ensure that all findings/discrepancies resulting
from the independent audit system are corrected in a timely manner, and to enable
the accountable manager to remain informed of the state of compliance and any
safety issues. The accountable manager should hold routine meetings to check
the progress on clearing outstanding findings/discrepancies. In the larger repair
stations, such meetings may be delegated on a day-to-day basis to the quality
manager as long as the accountable manager meets at least once per year with
the senior staff involved to review the overall performance.
1. Where the
repair station has associated
14 CFR part 121 line stations, the system should describe how these are
integrated into the system and should specify the need to audit each line station
at least once per year.
NOTE: Inspectors are not required to survey a part
121 line station for compliance with an EASA supplement. If an inspector
is responsible for an air carrier with line stations outside the inspector’s
geographic area, the inspector should request assistance from the office with
the geographic responsibility for the line station.
2. Note that
when applicable, each line station that is used by an aircraft operated under
the regulatory control of an EU operator in accordance with the conditions of
the EASA/FAA MIP should be listed giving its location and the basic maintenance
capability at each such location.
3. Any line
station process or procedure that differs from the processes or procedures specified
14 CFR part 145 RSM/QCM or is not referenced in the manual needs to be specified.
4. The QMS
as specified in this subparagraph 17b must be extended to include the need for
the accepted organization to audit the listed line station locations.
5. One example
of the particular product line should be used as the basis of each audit, except
in the case of store audits, for which a random selection of parts should be
used. It therefore follows that a repair station maintaining aircraft and engines
(off aircraft) and mechanical parts (off aircraft) would need to carry out three
audit sample checks each year with the particular product type changed each
year. An example audit program is attached.
6. A report
should be raised for each audit carried out describing what was checked and
any resulting findings/discrepancies. The report should be sent to the relevant
department for rectification action giving target rectification dates. The relevant
department is required to rectify the findings/discrepancies and
inform the quality department.
7. The example
schedule in MIP-G (see subparagraph 12-526D) contains an example of an audit
program that can be applied in the aircraft hangars, engine workshops, and component
workshops. Not all subjects will apply in all cases, and the example audit program
should be used as a starting basis and then altered to fit the particular type
of repair station, as needed.
8. A product
should be selected in each hangar and each workshop and the example audit program
applied at least once per year (twice per year in the case of a repair station
with fewer than 10 people and which chooses to contract the audit to an outside
person) with procedures that are common throughout the repair station, the procedure
need only be audited once per year if there are no problems.
NOTE: An applicant may use the procedures specified
AC 145-5 to develop audit procedures for its QMS; however, the applicant
should audit those applicable audit subjects specified in the EASA supplement.
18) Provision of Hangar Space for Aircraft
Maintenance. If the applicant has an airframe or limited airframe rating, ensure
this section describes the procedures the applicant will use to ensure it has
sufficient hangar space available for aircraft operated under the regulatory
control of an EU member state undergoing maintenance and/or alteration. There
is a need to ensure hangar space will be available when the customer agrees
on the contract for maintenance and alterations. This is only applicable to
repair stations with airframe and/or limited airframe ratings, except in the
case of line maintenance performed by an applicant that is also operating as
14 CFR part 121 air carrier.
19) Contracted Maintenance.
a) When part of the maintenance is contracted
to another organization, the repair station must ensure that the other organization
is either approved by EASA for the maintenance it carries out, or such contracted
organization must work under the repair station contracted provisions stated
14 CFR part 145.
b) All organizations contracted by the
repair station must be listed by the repair station stating whether each organization
is EASA-approved or under the repair station’s control via
14 CFR part 145.
20) Training and Qualification in Human
a) Until the FAA officially approves
repair station training programs, the inspector must confirm if the EASA supplement
contains procedures for initial and recurrent training programs that address
training and qualifications in human factors.
NOTE: Training in maintenance human factors is an
essential part of an FAA-approved training program. The repair station’s submitted
training program and any revision thereto must include human factors elements.
The FAA will not prescribe which human factors elements to include, but those
elements should focus on aviation maintenance and safety-related issues. If
human factors were not included, their exclusion would hinder the training program
AC 145-10, Repair Station Training Program, for additional information.)
b) The FAA concurs with the European
Authorities that human factors training related to maintenance practices would
provide an additional margin of safety to the repair station industry. A human
factors training program should be related to maintenance practices where possible.
The following are suggested human factors elements for inclusion in a repair
station training program:
General/introduction to human factors,
Safety culture/organizational factors,
Types of errors in maintenance tasks,
Human performance and limitation,
Situational awareness, and
21) Appendix 1–Sample Audit Program.
EASA’s MIP-G references two types of audits: procedural audits and product audits.
Verify that a sample of an audit schedule for one product line is included in
appendix 1 of the supplement. The audit schedule must show auditing the shops
procedures to ensure compliance with 14 CFR parts
145 as well as the EASA supplement. This audit program can be applied in
the aircraft hangars, engine workshops, or component workshops. Not all audit
subjects will apply in all cases, and the sample audit program should be used
as a starting basis and then altered to fit the particular type of repair station.
22) Appendix 2—Line Stations. If the
applicant is an air carrier operating line stations under
14 CFR part 121, ensure each line station used by an EU-regulated aircraft
is listed in appendix 2 of the supplement. Ensure this list includes the location
and capabilities of the line stations. The line stations can be accepted under
EASA Part-145 only if the air carrier holds a
14 CFR part 145 certificate for all operated aircraft types for at least
one of its base maintenance facilities. The applicant’s QMS must cover the air
14 CFR part 145 certificate, and the line stations. Ensure the applicant’s
QMS includes provisions to audit the listed line station locations.
23) Appendix 3—Sample Dual Release FAA
Form 8130-3. Ensure the applicant has procedures to guarantee that FAA Form
8130-3, is completed inspected in accordance with the current revision of Order
8130-21 when being used as a maintenance release. The supplement will have a
completed Form 8130-3 with the dual release and instructions on how to complete
C. Perform a Facilities Inspection
as Applicable. If an amendment to an EASA supplement includes a change to
the facilities or equipment, the inspector must inspect those facilities (see
volume 2, chapter 11, section 6).
12-530 TASK OUTCOMES.
A. Complete the PTRS Record.
B. Complete the Task. Completion
of this task will result in one of the following actions:
1) Acceptance of the EASA supplement/supplement
a) Continuing to process the applicant’s
request for EASA Part-145 approval inspected in accordance with
volume 2, chapter 11, section 6, if applicable;
b) Preparing and transmitting a cover
letter or transmittal document to the repair station that indicates FAA acceptance
of the supplement or revision;
c) Returning one copy of the EASA supplement/supplement
revision to the applicant after receipt of its EASA Part-145 approval certificate;
d) Filing a copy of the EASA supplement/supplement
revision as follows:
1. For an
original EASA supplement, file a copy of the EASA supplement including a copy
of the acceptance letter/transmittal document in the certificate holder/applicant’s
office file; or
2. For a revision,
remove the affected pages and insert the revised pages into the current EASA
supplement and update the supplement control system. Revisions to the supplement
are considered accepted by the FAA unless the repair station is notified otherwise
by the FAA.
2) Rejection of the EASA supplement/supplement
a) Returning all copies of the EASA
supplement/supplement revision to the applicant with a letter explaining the
b) Explaining to the applicant that
the EASA supplement/supplement revision must be corrected and resubmitted to
proceed with the process of seeking EASA Part-145 approval.
C. Document The Task. File all
supporting paperwork in the certificate holder/applicant’s office file and update
the Vital Information Subsystem.
12-531 FUTURE ACTIVITIES. None.
RESERVED. Paragraphs 12-532 through 12-546.