8900.1 CHG 674


Indicates new/changed information.


Section 3  FAA Independent Inspections of EU-Based Approved Maintenance Organizations

3.1    GENERAL.

3.1.1    Purpose. This section provides guidance to aviation safety inspectors (ASI) on conducting a Federal Aviation Administration (FAA) independent inspection of a European Union (EU)-based Approved Maintenance Organization (AMO). Annex 2, Maintenance, paragraph 4.7 indicates that the FAA may conduct independent inspections of AMOs to address specific safety concerns, per Article 15.B of the United States (U.S.)/EU Aviation Safety Agreement (the Agreement). In this case, the FAA must inform the aviation authority (AA) and the European Aviation Safety Agency (EASA) (either directly or through the AA) that the FAA will make such inspections. ASIs must use this section with the Maintenance Annex Guidance (MAG). However, the MAG supersedes this section if conflicts exist between the two documents.

3.1.2    Scope. This section is applicable to all FAA International Field Offices (IFO) and Flight Standard Service (FS) offices having responsibilities associated with EU Member States.

Note:  See Volume 12, Chapter 7, Section 1 for background information about the MAG and the U.S./EU Aviation Safety Agreement, which includes Annex 2. Both the MAG and the Agreement are located at https://www.faa.gov/aircraft/repair.

3.1.3    Reporting System. Use Safety Assurance System (SAS) automation and the associated Data Collection Tools (DCT).


3.2.1    Prerequisites:

    Knowledge of Title 14 of the Code of Federal Regulations (14 CFR) parts 43 and 145.

    Successful completion of the Airworthiness Inspector Indoctrination course(s), or equivalent.

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

    Successful completion of FAA Course 21058, Certification and Surveillance of Part 145 Repair Stations, or equivalent.

    Successful completion of FAA Course 27200002, Understanding the US/EU Aviation Safety Agreement (2018 revision).

    Knowledge of the Agreement.

    Knowledge of the MAG.

3.2.2    Coordination. This task requires coordination with:


    The AA of the Member State in which the AMO is located,

    International Program Division,

    FAA Coordinator (International Field Office Management Branch),

    FAA Coordinator (IFO),

    Aircraft Maintenance Division, and



3.3.1    References (current editions):

    Title 14 CFR Parts 43 and 145.

    Volume 1, Chapter 3, Section 1, Safety Assurance System: Responsibilities of Aviation Safety Inspectors.

    Volume 2, Chapter 11, Certification of a Part 145 Repair Station.

    Volume 10, Safety Assurance System Policy and Procedures.

    Volume 14, Chapter 1, Section 2, Flight Standards Service Compliance Action Decision Procedure.

    FAA Order 1350.14, Records Management.

    FAA Order 2150.3, FAA Compliance and Enforcement Program.

    The Agreement Between the United States of America and the European Union on Cooperation in the Regulation of Civil Aviation Safety (the Agreement).

    Maintenance Annex Guidance Between the Federal Aviation Administration for the United States of America and the European Aviation Safety Agency for the European Union (the MAG).

    Bilateral Oversight Board (BOB) decisions.

3.3.2    Forms:

    FAA Form 8000-4, Air Agency Certificate.

    FAA Form 8310-3, Application for Repair Station Certificate and/or Rating.

    EASA Form 3, Maintenance Organisation Approval Certificate.

3.4    GENERAL.

3.4.1    Authority for Independent Inspections. Annex 2, paragraph 4.7 indicates the FAA may conduct independent inspections of EU-based AMOs with specific safety concerns. The FAA Coordinator (International Field Office Management Branch), the EASA Coordinator, and the Aircraft Maintenance Division must coordinate independent inspections.

3.4.2    Possible Causes for an Independent Inspection. The Aircraft Maintenance Division or the International Field Office Management Branch may request an independent inspection when they find:

    Specific safety concerns resulting from a sampling inspection;

    A safety-related issue, such as an incident, accident, or occurrence;

Indicates new/changed information.

    Failure to comply with Annex 2; or

    Identified risk or other Sampling Inspection System (SIS) Risk Decision Tool for safety systems analyses.


3.5.1    Determine the Need for an Independent Inspection. The FAA Coordinator (IFO) assigned for an EU country, or the IFO manager, may determine an independent inspection is necessary, based on safety concerns or identified risks. Once the need is determined, the IFO manager will contact the FAA Coordinator (International Field Office Management Branch) and provide written justification/documentation of the request.

a)    The FAA Coordinator (International Field Office Management Branch) will review the request and risk justification for the independent inspection. The International Field Office Management Branch will forward the written request for concurrence to the Aircraft Maintenance Division.

b)    Upon receiving the Aircraft Maintenance Division concurrence, the FAA Coordinator (International Field Office Management Branch) must inform the AA that the IFO will make such inspection(s).

c)    The IFO manager will assemble the IFO team. The FAA Coordinator (IFO) assigned for that particular country should be the Team Lead.

3.5.2    Scope of an Independent Inspection. The FAA Coordinator (International Field Office Management Branch) will determine if the independent inspection requires a complete facility inspection or a focused inspection of a specific area of concern. The IFO team should conduct independent inspections using the AMO’s maintenance organization exposition (MOE), which is its Repair Station Manual (RSM), and should also use the FAA supplement, per the MAG.

Note:  The IFO team may also inspect for compliance with part 145 regulations that are equivalent and not identified as a special condition. However, the FAA teams normally limit inspections to the special conditions unless events lead them into additional areas. Any discrepancies that are uncommon to the special conditions should be communicated to the FAA Coordinator (International Field Office Management Branch).

3.5.3    Job Aids for the Independent Inspection. The IFO team may use a combination of the AMO SIS forms found in the MAG, such as Audit Report 2, AA Recommendation of an FAA-certificated AMO; Audit Report 3, SIS Audit of an FAA-certificated AMO Located in the EU; or other means to record any discrepancies.

3.5.4    Closeout Actions. The FAA Coordinator (IFO) may work with the applicable AA to ensure that corrective actions will resolve any identified risks. Conclude the inspection by taking the following actions:

a)    Prepare for the AMO Debriefing. The IFO team will meet to present their findings and recommendations prior to debriefing the AMO. At the meeting, the IFO team should agree on a timeframe for the AMO to provide the IFO with the required corrective action or a corrective action plan (CAP). The AMO should clearly understand the requirements for corrective action.

b)    Debrief the AMO. After completing the independent inspection, the IFO team will debrief the AMO.

1)    The IFO Team Lead must inform the AMO in writing of the identified items and provide the required timeframe for corrective action. The AMO must forward all corrective action or CAPs to the IFO team for review. The AA may assist to monitor and follow up with corrective actions as needed.

2)    The FAA Coordinator (International Field Office Management Branch) must inform the AA within 15 calendar-days after the independent inspection took place.

3)    The FAA Coordinator (International Field Office Management Branch) will provide a copy of the discrepancies to the Aircraft Maintenance Division.

c)    Acceptance of Corrective Actions of AMO. Once the AMO has forwarded the corrective action of the discrepancies to the IFO, the Team Lead will review the corrective actions.

1)    Once acceptable, the IFO Team Lead will provide written correspondence to the AMO indicating the corrective action to the identified items found during the independent inspection is acceptable and closed. Forward a copy to the AA and the FAA Coordinator (International Field Office Management Branch).

2)    The FAA Coordinator (International Field Office Management Branch) will provide a copy to the Aircraft Maintenance Division for closure.


3.6.1    Follow SAS Guidance for Module 4, Data Collection and Data Reporting, and Module 5, Analysis, Assessment, and Action (AAA).

a)    Use SAS for data collecting, data reporting, AAA, and the Action Item Tracking Tool (AITT).

b)    Document any discrepancies in SAS using a Dynamic Observation Report (DOR). This will provide information on repair stations for data risk analysis and assessment and will provide an improved method of identifying AMOs for independent inspections.

Note:  The FAA will charge the inspected AMO all costs associated with FAA independent inspections, such as travel, lodging, or inspector time. Because this task is a safety inspection related to the AMO’s part 145 certificate, it is justifiable per certificate renewal requirements in Advisory Circular (AC) 187-1, Flight Standards Service Schedule of Charges Outside the United States.

3.6.2    Document the Task. File all supporting paperwork in the office file for the certificate holder.

3.6.3    Compliance Action. Follow the process contained in Volume 14, Chapter 1, Section 2 to identify the root cause that led to any deviations from the rules, standards, or procedures. Resolve the deviations, and return the repair station to full compliance.

3.7    FUTURE ACTIVITIES. Follow the MAG procedures and Volume 10 SAS guidance to plan future risk‑based surveillance in SAS.