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Volume 12 international aviation

CHAPTER 8 evaluate an EASA supplement to a repair station manual/quality control manual

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.

12-526       GENERAL.

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 be submitted.

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.
4)       Introduction.
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 Maintenance.
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 http://www.easa.eu.int.

12-527       PREREQUISITES AND COORDINATION REQUIREMENTS.

A.       Prerequisites:

·         Knowledge of the regulatory requirements of 14 CFR parts 43 and 145;

·         Knowledge of the requirements of volume 2, chapter 11, section 6 and EASA MIP-G;

·         Successful completion of the Airworthiness Inspector Indoctrination course or equivalent;

·         Successful completion of the foreign and domestic repair station training course 21058; and

·         Previous experience with certification or surveillance of 14 CFR part 145 repair stations.

B.       Coordination. This task requires coordination with:

·         The applicant (repair station),

·         The applicant’s principal maintenance inspector (PMI) or principal avionics inspector (PAI),

·         The FAA regional EASA coordinator, and

·         FAA regional and district offices, as appropriate.

12-528       REFERENCES, FORMS, AND JOB AIDS.

A.       References (current editions):

·         Title 14 CFR parts 43 and 145,

·         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 Visit,

·         EASA MIP-G, and

·         Advisory Circular (AC) 145-5, Repair Station Internal Evaluation Programs.

B.       Forms:

·         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 (TBD).

12-529       PROCEDURES.

A.       Receive the Applicant’s EASA Part-145 Supplement/Supplement Revision.

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 identified.)

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 on its 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 43 and 145 and EASA requirements.
a)       Release to service of components up to and including complete powerplants must be carried out in accordance with part 43, § 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 8130.21.

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 release.
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: EASA.145”.

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.

1.       Component 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 by EASA).

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 43 requirements.

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 rating.
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 to service.
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 § 43.11.

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 system.
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:

1.       Procedural 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.

2.       Product 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 in the 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 in 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 a 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 in 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 Factors.
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 approval. (See 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,

·         Statistics,

·         Safety culture/organizational factors,

·         Human error,

·         Types of errors in maintenance tasks,

·         Human reliability,

·         Human performance and limitation,

·         Vision,

·         Hearing,

·         Stress,

·         Situational awareness, and

·         Workload management.

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 43 and 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 carrier certificate, 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 the form.

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 revision by:
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; and
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 revision by:
a)       Returning all copies of the EASA supplement/supplement revision to the applicant with a letter explaining the deficiencies; and
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.