EASA Regulation Structure Gorham 2014.86110919

EASA Regulatory structure
Design and maintenance related to airworthiness
Gorham J.H.A. van den

Atlanta Elshout
workshop Compliance
Verification
Engineer within
KLM EASA DOA
March 2014
Disclaimer
• These slides are for training purposes only and are a

derivative from original regulation content at time of
preparation of this workshop
• KLM is not in any way responsible for the data, or the
opinions presented
• For formal purposes use original regulation text as
published by the authorities
Note:
– Contents limited to commercial civil aviation
• Only Initial + Continuing airworthiness
• Airport and airspace regulations not included
• Limited to large aircraft
– If You have a version with note pages: These notes contains parts of original regulation content based on
data as published in 2013. Also this data is for training purposes only and not necessary the latest data
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KLM wet en regelgeving - version CG 27/03/2014
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Contents
• Regulating bodies / jurisdictions:

– ICAO, EASA, FAA etc.
• Structure jurisdiction EASA
– Law EU + EASA decisions
– Initial airworthiness
• Part 21 design + production
– Continuous airworthiness
• Part M continuing airworthiness
• Part 145 maintenance organisation
• Part 66/147 Certifying staff/training
• Relation EASA – FAA
– Bilateral agreements
– differences between FAA and EASA
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Regulating Bodies
Aviation is an international Industry and requires an

international Fundament
ICAO
http://www.icao.int/Pages/default.aspx
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ICAO International Civil Aviation organisation
Key Objectives:
• Aviation safety + security,
– Incl. regulation, accident investigation and SMS
• Environmental + sustainable development of air transport
– Incl. emission and noise requirements
History:
• Treaty of Paris of 1919
• Created by 1944 Chicago convention (United Nations)
• ICAO started in 1947.
• 191 states connected
Jurisdiction:
• ICAO treaties have no jurisdiction, but
– content is written into national law and regulations
• National Aviation Regulation jurisdictions follow ICAO
International agreed standard
Note:
– Reciprocal tax exemption between member states
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National Aviation regulating jurisdictions

• USA FAA Federal Aviation Authorities
• Europe
– Up to July 2003
• all European countries had their civil aviation jurisdictions
• JAA (joint aviation authorities)was first step to standardization
– Joint design + maintenance standard still in national law controlled by local
authorities
– Present Europe EASA European Aviation Safety Agency
• EEC + Iceland, Norway, Switzerland
• collaboration between European Commission + aviation authorities
Member States
• Replaced jurisdiction role of national authorities,
– national authorities responsible for supervision / audits
• China CAAC Civil aviation authorities China
• United Arab Emirates GCAA General Civil Authority
• Indonesia DGAC Directorate General Air Common.
• Singapore CAAS Civil Aviation Authority Singapore
• etc.
Note: Bilateral agreements exist between governments / states

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EASA
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Relation EASA parts

Continuing airworthiness Crew
Operations
Airport
Part – M NAV, ATC
Maintenance program etc
Initial
Part - 145 airworthiness
Approved Part – 21
Part - 147
Maintenance Design
Training Institute
Part - 66 Organisation + production
Certifying
Staff
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EASA Rulemaking regulations structure
http://easa.europa.eu/regulations/regulations-structure.php
EU Reg 216/2008
Reg 748/2012 Regulation

part 21 2024/2003
Reg
Part M, 145, 965/2012
147, 66,
AMC20
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EASA regulation structure airworthiness 2014

Regulating type Regulating authority
Basic
regulation
EU law European Parliament
216/2008
Implementation rules
Implementation rules Commission Commission European Commission
= EU law regulation regulation
748/2012 2042/2003
Initial Continuing
Airworthiness airworthiness
Including Annex I = Part M
environmental cert. Annex II = Part 145
+Production Annex III = Part 66
Annex I = Part 21 Annex IV = Part 147
EASA EASA decisions internal

decisions
AMC Part 21 AMC EASA
•ED Decision 2012/020/R • ED 2003/19/RM
•CS (Certification specs) • GM (Guidance Material)
•AMC (Acceptable Means of Compliance)
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Design + Production
PART 21
•Commission J.H.A. van den

regulation (EC) Elshout
no 748/2012 SPL/CG
•Guidance KLM
material
ED Decision
2012/020/R
-Part 21
-Certification
Specs
-Production
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Initial Airworthiness = Design + production Part 21

Commission regulation 748/2012 amended by 69/2014
Guidance material ED Decision 2012/020/R
Scope:
• common technical requirements
• administrative procedures for airworthiness + environmental
certification of products, parts + appliances
Specifying:
• Issue of
– airworthiness codes = certification specifications = design requirements
– type-certificates (TC)+ supplemental type-certificates (STC)
– certificates of airworthiness, permits to fly + release certificates
– repair design approvals
– noise certificates
– airworthiness directives (AD)
• Show compliance with environmental protection requirements
• certification of design + production organisations (DOA + POA)
• certification of parts + appliances
• Identification (products, parts and appliances)
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Part 21 contents
SECTION A TECHNICAL REQUIREMENTS
• SUBPART A — GENERAL PROVISIONS
• SUBPART B — TC AND RESTRICTED TC (Type Certificate)
• (SUBPART C — NOT APPLICABLE
• SUBPART
D — CHANGES TO TC AND RESTRICTED TC
• SUBPART
E — STC (SUPPLEMENTAL TYPE-CERTIFICATES)
• SUBPART
F — PRODUCTION WITHOUT POA
• SUBPART
G — POA (PRODUCTION ORGANISATION APPROVAL)
• SUBPART
H — CERTIFICATES OF AIRWORTHINESS + RESTRICTED
CERTIFICATES OF AIRWORTHINESS
• SUBPART I — NOISE CERTIFICATES
• SUBPART J — DOA (DESIGN ORGANISATION APPROVAL)
• SUBPART K — PARTS AND APPLIANCES
• (SUBPART L — NOT APPLICABLE)
• SUBPART M — REPAIRS
• (SUBPART N — NOT APPLICABLE)
• SUBPART O — ETSO (EUROPEAN TECHNICAL STANDARD ORDER)
• SUBPART P — PERMIT TO FLY
• SUBPART Q — IDENTIFICATION OF PRODUCTS, PARTS + APPLIANCES
SECTION B PROCEDURES FOR COMPETENT AUTHORITIES
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Industry terms
• PRODUCT
– Aircraft, Engine, Propeller
• their design requires a type certificate
• TC Type Certificate
– Design approval of a product
• STC Supplemental Type Certificate
– Design approval of a major change to a product
• TC basis
– Amendment level of certification specs used for Type Certificate
• Appliance
– any instrument, equipment or accessory used in operating an aircraft in
flight, but is not part of airframe, engine or propeller
• Certification
– Legal recognition that such a product, service, organisation or person
complies with applicable requirements
• Maintenance
– overhaul, repair, inspection, replacement, modification or defect
rectification of an aircraft or component
• except pre-flight inspection
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EASA Certification specifications
http://easa.europa.eu/agency-measures/certification-specifications.php
multiple ED decisions; Initial issues + amendments
CS-22 Sailplanes and Powered Sailplanes

CS-23 Normal, Utility, Aerobatic and Commuter Aeroplanes
CS-25 Large Aeroplanes
CS-27 Small Rotorcraft
CS-29 Large Rotorcraft
CS-31HB Hot Air Balloons
CS-34 Aircraft Engine Emissions + Fuel Venting = ICAO
CS-36 Aircraft Noise refers to ICAO
CS-APU Auxiliary Power Units
CS-AWO All Weather Operations
CS-E Engines
CS-ETSO European Technical Standard Orders
CS-Definitions Definitions and Abbreviations
CS-P Propellers
CS-VLA Very Light Aeroplanes
CS-VLR Very Light Rotorcraft
AMC-20 General Acceptable Means of Compliance for
Airworthiness of Products, Parts and Appliances
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EASA Design approvals Part 21

• Type Certificate (TC) Subpart B
– Design approval of a product
– Changes to the TC by TC holder Subpart D
Non TC holder
• Major subpart E
• Minor through agency or DOA subpart J
• Supplemental type-certificate (STC) Subpart E
– Design approval of major change to a product
• Design organisation approval (DOA) Subpart J
– normal approach for
• type certification,
• supplemental type certification
• approval of changes to type design
• approval of repair design
• European Technical Standard Order (ETSO) Subpart O
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Approval and compliance Part21
Approval of a design, repair or change requires:

• compliance with
– TC basis
• Related to specific certification specification revision
– environmental protection requirements
– amendments to those certification specifications
– special conditions in the Type Certificate
• Submittal of all necessary substantiation data
• Declare compliance with certification specifications and
environmental protection requirements
– Latest (CS) requirements except if impractical but not older
than TC basis
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TC Type Design Part 21 Subpart B

The Type Design of a product consists of:
• Drawings + specifications showing compliance with
– type-certification basis*
– environmental protection requirements
• Information on materials, processes and methods of manufacturing
and assembly
• approved airworthiness limitations section of the instructions for
continued airworthiness (chapter 5)
• Data necessary to allow
– determination of airworthiness,
– characteristics of noise,
– fuel venting
– exhaust emissions.
*TC basis = Amendment level of certification specs used for Type Certificate
– specific revision of design requirements
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Type Certificate (TC) Part 21 Subpart B
Document certifying a Product
The “Type Certificate” includes

– type design
– Type Certificate Data Sheet (TCDS) to document the design basis
– operating limitations
– applicable type-certification basis + environmental protection
requirements + other conditions or limitations.
The aircraft TCDS includes noise

The engine TCDS includes emission compliance
TC holder is responsible for the type design of complete product

– including all work done by subcontractors
TC holder has to publish

– Changes (service bulletins)
– Maintenance manuals incl. inspection and Repairs
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Supplemental type certificate (STC)

Part 21 Subpart E
System for major changes
Requirements:
• Similar to requirements TC holder
• But non TC holder parts have obligation for part
marking by “EPA marking”
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Part 21 DOA: Design organisational Approval Subpart J
EASA approved organisation responsible for design of
• products, parts, appliances and/or
• changes or repairs
Privileges: Design activities within its scope of approval. (21.A.263)
• Classify changes + repairs as ‘major’ or ‘minor’
• Approve minor changes and minor repairs (under Subpart D)
• Issue compliance documents to obtain:
– approval of flight conditions required for a permit to fly
– TC, STC or ETSO authorisation
– major repair design approval
• Issue information or instructions containing the formal DOA statement:
– ‘The technical content of this document is approved under the authority of DOA
ref. EASA. 21J. [XXXX]’
• Approve minor revisions to aircraft flight manual + supplements,
• Approve major repair design to products or APU for which it holds (S)TC or ETSO
• Approve the conditions under which a permit to fly can be issued
• Issue permit to fly for aircraft it has designed or modified, or for which it has
approved the conditions under which the permit to fly can be issued
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DOA: RELATIONSHIPS BETWEEN DESIGN, DAS

(DESIGN ASSURANCE) + TYPE INVESTIGATION
Subpart J DAS GM 1 to 21.A.239(a)

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PART 21 PARTS AND APPLIANCES SUBPART K
Compliance of parts + appliances

to be installed in a type-certificated product shall be :
• in conjunction with the type-certification procedures of
– Subpart B (TC),
– Subpart D (changes to TC) or
– Subpart E (STC) for the product in which it is to be installed;
or
• where applicable, under the ETSO authorisation procedures
(Subpart O)
or
• in the case of standard parts, in accordance with officially
recognised Standards.
21.A.303
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Classification of changes + repairs PART 21

• Minor change
– No appreciable effect on mass, balance, structural strength,
reliability, operational characteristics, noise, fuel venting, exhaust
emission, or other characteristics affecting airworthiness of
the product.
• all other changes are “major changes”
– Minor changes shall be classified and approved (21.A.95)either:
• by the Agency or
• by an appropriately approved design organisation (DOA)
– Major change
• Approval by agency
• Declaration by DOA (recommend for approval)
– Repair classification in accordance criteria “change of design”
Notes:
• “airworthiness” is interpreted in the context of a product
– in conformity with type design and
– in condition for safe operation
21.A.91 + 21.A.435
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Appreciable effect Part 21
A change has
“appreciable effect” on
“other characteristics affecting airworthiness of
the product” and should be classified major
when one or more of following conditions are met:
– Requires adjustment of TC
– New interpretation of requirements used for TC basis,
– Demonstration of compliance uses methods not previously
accepted as appropriate for
• the nature of the change or
• similar changes to other products designed by applicant.
– Extent of new substantiation data is considerable.
– The change alters airworthiness and / or operating limitations.
– The change is
• made mandatory by an AD or
• terminating action of an AD.
– The change introduces or affects functions where failure effect
is classified catastrophic or hazardous.
GM 21.A.91
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Risk assessment during design
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Examples of major Changes per discipline
PART 21 Appendix A to GM 21.A.91
Sections of list for complete list see ref.) Subpart D appendix A to GM21.A91
1. Structure Changes
– such as cargo door cut-out, fuselage plug, change of dihedral, addition of floats;
– to materials, processes or methods of manufacture of primary structural elements, such
as spars, frames and critical parts;
– that adversely affect fatigue, damage tolerance or life limit characteristics
– that adversely affect aeroelastic characteristics.
6. Engines Changes:
– that adversely affect operating speeds, temperatures, + other limitations.
– that affect or introduce parts (identified by CS E-510) where the failure effect has been shown
to be hazardous.
– that affect or introduce engine critical parts (CS E-515) or their life limits.
– to a structural part which requires a re-substantiation of the fatigue + static load
determination used during certification.
– to any part of the engine which adversely affects the existing containment capability.
– that adversely affect fuel, oil and air systems, which alter method of operation, or
require reinvestigation against the TC basis.
– that introduce new materials or processes, (particularly on critical components)
9. Power plant Installation Changes which include:
– control system changes which affect the engine/propeller/airframe interface;
– new instrumentation displaying operating limits;
– modifications to the fuel system and tanks (number, size and configuration);
– change of engine/propeller type
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Critical parts PART21

No EASA definition in part 21 but statements in EASA faq
http://www.easa.europa.eu/rulemaking/faq/commission-regulation-1702-2003-initial-airworthiness.php
• Rotorcraft: the failure of it could have a catastrophic effect
• Engines: means a part that relies upon meeting prescribed integrity
specifications of CS-E 515 (engine critical parts) to avoid its Primary
Failure, which is likely to result in a Hazardous Engine Effect. (CS-E 15)
• EU-US bilateral:a part identified as critical by the design approval
holder during product type validation process, or otherwise by the
exporting authority. Typically, such components include parts for
which a replacement time, inspection interval, or related
procedure is specified in the Airworthiness Limitations section
or certification maintenance requirements of the manufacturer's
maintenance manual or Instructions for Continued Airworthiness
Repairs to engine or APU critical parts would normally only be

accepted with the involvement of the TC holder (AMC 21.A.433)
Note:
Some OEM’s created “Critical Influencing Parts“.
• These are NOT critical parts,
• this is not EASA/FAA approved text in Airworthiness Limitations section;
• also no replacement time or inspection interval specified
• Refers to formal FAA guidance in place by AC 33-8 and 33-9
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Classifcation of changes (21A.91)
Changes
Appreciable effect to: Yes

weight, balance, structural strength,
Reliability, operational characteristics
of product
NO
•Adjustment of certification basis,

•New interpretation certification basis,
NO •Additional compliance demonstration, Yes
•Substantiation data + reassessment considerable,
•Alters limitations approved by agency
•Mandated by AD
•Introduces function where failure condition =
Catastrophic or hazardous
Reclassify to minor
MINOR by agency
MAJOR
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Repair Part 21 Subpart M 21A.431
Elimination of damage and/or restoration to airworthy condition

– Elimination of damage by replacement without design activity is
maintenance task and does not require design approval.
Repair design approval
through
– the Agency = EASA
– the (S)TC holder,
– DOA
Approved data
– Published in “instructions for continued airworthiness”
– data which is approved either by the Agency, (S)TC holder or by DOA
Notes
– classification in accordance with the criteria for change in the type design.
– When a repaired product is released into service before fatigue + damage
tolerance evaluation is completed, release should be for a limited service
period, defined at issue of repair.
– A repair of a TSO except APU is a change to the product
– A maintenance organisation may manufacture parts for repair purposes
according approved data + procedures. (21.A.439)
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Production of Repair Parts
Part 21 Subpart K 21.A.439
Parts + appliances to be used for the repair shall be

manufactured in accordance with data based upon design
data as provided by repair design approval holder:
• under Subpart F (production without POA);

– issuance of a POA inappropriate; or
– certification / approval of a part under this Subpart is needed
pending issuance of a POA
or
• by an organisation appropriately approved in accordance
with Subpart G (POA);
or
• by an appropriately approved maintenance organisation
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Production Organisational Approval (POA)

Part 21 Subpart G
• Scope
– Production approval process for organisations producing
• aeronautical products, parts, appliances and/or materials
• intended for airborne use
• as part of a type-certificated product
• Requirements POA
– POA – DOA contractual relation (21A.4)
– Approved design (drawings, specifications + other technical information)
– procedure manual = POE (production organisation exposition)
– Quality system, Facility, equipment, personnel + management etc
Part 21 Subpart F Production without POA when

– POA under Subpart G would be inappropriate; or
– certification / approval of a product, part or appliance is needed pending
issuance of a POA under Subpart G
• limited duration not exceeding one year
• manufacturer of a product, part or appliance being manufactured under Subpart F
shall make each product, part or appliance available for inspection
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Standard parts Part 21 Subpart K 21.A.303
Specified by an approved design

• Do not requiring EASA form 1 release certificate
• All design, manufacturing, inspection data and marking
requirements necessary to demonstrate conformity of that
part should be in the public domain and published or
established as part of “officially recognized Standards”
“officially recognized Standards”

– Those standards established or published by an official body,
which are widely recognized by the air transport sector as
constituting good practice
e.g.: NAS, AMS etc.
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European Technical Standard Order (ETSO)

Part 21 Subpart O 21.A.602B
ETSO items / components are used and certified for
multiple aircraft types / independent from TC
E.g.: safety belts, APU
• ETSO is a detailed airworthiness specification issued by the
Agency as a minimum performance standard for specified
articles incl. the Auxiliary Power Unit.
• ETSO authorisation requires separate approvals for
– Production,
• POA, issued in accordance with Subpart G,
– or temporary through compliance with Subpart F procedures
– Design:
• for an APU holding a DOA;
• for all other articles using procedures setting out the specific
design practices, resources and sequence of activities
necessary to comply with this Annex I (Part 21).
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EPA European Part Approval Part21
Article produced in accordance with approved design data

not belonging to the TC holder of the related product
– except for ETSO articles
• Holders of repair or change design approvals (DOA,

STC) are required to specify “EPA” marking for added
parts
21.A.109 + 21.A.804
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Airworthiness directives Parts 21 21A.3B
AD NOTES:
Issued or adopted by the Agency which mandates actions to be

performed on an aircraft to
• restore an acceptable level of safety,
• when evidence shows that the safety level of this aircraft may
otherwise be compromised
When authority of a (EASA) Member State receives an

airworthiness directive from authority of a non-member
State, that airworthiness directive shall be transferred to the
Agency for dissemination (21B.60)
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Permit to fly Part 21
Issued to aircraft that

• do not meet airworthiness requirements but
• are capable of safe flight under defined conditions
• for following purposes:
– Development + Showing compliance with regulations or certification specs.
– Design or production organisations crew training
– Production flight testing new aircraft
– Flying aircraft under production between production facilities
– Flying aircraft for customer acceptance, delivering or exporting
– Flying aircraft for Authority acceptance
– Market survey, including customer’s crew training, exhibition, air show
– Flying aircraft to location for maintenance, airworthiness review, storage
– Flying aircraft at weight in excess of max. certificated takeoff weight
• flight beyond normal range
– Before conformity to environmental requirements
– Record breaking, air racing
– if cert. of airworth. not appropriate; non-commercial/complex; only owner
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instructions for continued airworthiness

Part 21
Examples of part 21 created ICA data
• Manufacturers Structural Repair Manual,
• Maintenance / Engine Manuals provided by the holder of
– the TC and STC,
– design approval or
– ETSO authorisation as applicable
Publication requirement ICA for Holder of TC (21.A.61) and

minor change approval (amendment 21.A.107)
– furnish ICA / amended ICA to
• each known owner of one or more aircraft, engine or propeller
upon its delivery or upon issue of the first certificate of
airworthiness for the affected aircraft, whichever occurs later
• and thereafter make those instructions available on request to
any other person required to comply with any of the terms of
those instructions.
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Records Part 21
Design
• All relevant design information, drawings, test reports, incl.
inspection records for product tested, shall be held by the TC
holder at the disposal of the Agency and shall be retained
(throughout life) in order to provide the info. necessary to ensure
– the continued airworthiness,
– continued validity of the operational suitability data and
– compliance with applicable environmental protection requirements
of the product
Production
• Data which supports production conformity of a product, part,
or appliance should be kept for not less than 3 years from the
issue date of the related Statement of Conformity or Authorised
Release Certificate. (POA)
• Data considered essential for continuing airworthiness (design
related, departures etc.) should be kept throughout operational
life of the product, part or appliance.
Note: See also requirements for records for part M and part 145
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Continuing Airworthiness PART M/145/66/147
Part – M
Continuing airworthiness Commission J.H.A. van den
Maintenance program
regulations Elshout
2042/2003 SPL/CG
ED Decision No KLM
2003/19/RM
Part M
Part 145
Part 66
Part - 66 Part - 145 Part 147
Part - 147
Certifying Approved
Training
Staff Maintenance
Institute
Organisation
40
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continuing airworthiness
Commission regulations 2042/2003 + ED Decision No 2003/19/RM
Scope:
• Ensure continuing airworthiness of aircraft, incl. component
by
– Technical requirements +
– administrative procedures
Contents:
• Continuing airworthiness part M
– Operator responsibilities
• Maintenance organisation approvals part 145
– maintenance of large commercial aircraft + components
• Certifying staff part 66
• Training part 147
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:2003R2042:20120801:EN:PDF
http://easa.europa.eu/agency-measures/docs/agency-decisions/2003/2003-019-RM/decision_ED_2003_19_RM.pdf
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Continuing Airworthiness Part M
Requirements for air operations :

• Aircraft Maintained in airworthy condition
• Emergency equipment
• Certificate valid
• Maintenance according approved maintenance program
• Occurrence reporting system

– condition which endangers flight safety
2042/2003 ANNEX I (Part-M) M.A.201

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Aircraft maintenance program
PART M
Approved by
• authorities or
• through Continuing Airworthiness Management organisation –
“CAMO” approved by authorities
– Requires authority approved CAME (=Exposition Manual )
The aircraft maintenance programme must establish

compliance with instructions for airworthiness issued by:
• competent authority
– Including AD = airworthiness Directives
• holders of approved design data
– TC + STC,
– major repair design approval,
– ETSO authorisation
– relevant part 21 approvals (e.g. DOA)
• Instructions from
– Owner
– CAMO once approved 2042/2003 M.A.302
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PART M
records required for operator
Revision pending per NPA 2014-04
• Detailed maintenance records of aircraft + life limited components
– until superseded by new but not less than 36 months after release
• Total time in service of aircraft + life-limited components,
– at least 12 months after aircraft or component is withdrawn from service
• Time in service since last scheduled maintenance of life limited
component
– at least until scheduled maintenance is superseded by other scheduled
maintenance
• Current status of compliance with maintenance programme
– at least until aircraft or component scheduled maintenance superseded
by other scheduled maintenance
• Current AD status
– at least 12 months after aircraft or component permanently withdrawn
• Details of current modifications + repairs to aircraft, engine,
propeller and any other component vital to flight safety
– at least 12 months after they have been permanently withdrawn
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Maintenance organisation Part 145
Objective
• common technical requirements + administrative
procedures ensuring continuing airworthiness of aircraft,
including components
Scope 145.A.10
• Establishes requirements to be met by an organisation to
qualify for the issue or continuation of an approval for the
maintenance of aircraft and components
Maintenance
• overhaul, repair, inspection, replacement, modification or
defect rectification of an aircraft or component, with the
exception of pre-flight inspection
Authority oversight:
• designated authority of member state
• Non EASA country, authority =the Agency=EASA
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Component status part 145

• Components meeting requirements
– released on an EASA Form 1 or equivalent
• Unserviceable components
– require maintenance per Part 145
• Unsalvageable components AMC 145.A.42(d)
– Require mutilation
• Standard parts
– According industry specs +COC
• raw / consumable material
– documentation containing conformity to specification
– traceability to manufacturing / supplier
• Components with reached certified life limit
– Require mutilation AMC 145.A.42(d)
Notes
• Ensure component is eligible for the configuration
• Part 145 organisation may fabricate certain parts to be used in
work within its own facilities AMC 145.A.42(c)
– requires procedures in MOE and approved design
46
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Applicable Maintenance data part 145
Consisting of:
• Applicable requirements, procedures, operational directives or
information issued by authority responsible for oversight
• airworthiness directives
• Instructions for continuing airworthiness (ICA), issued by
– TC holders (manuals, service bulletins etc)
– STC holders,
– any other organisation required to publish such data by Part-21
– authority from third countries responsible for the oversight
• Mandated airworthiness data for aircraft or components
• applicable standards
– such as maintenance standard practices recognized by Agency as
good standard for maintenance
• Part 145 initiated changes if
– Fully equivalent and without design
• operator/customer controlled and provided maintenance data
EC No. 2042/2003 145.A.45 (b)
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Part 145 maintenance records

Revision pending per NPA 2014-04
• Record all details of maintenance work.
– Records necessary to prove all requirements are met for issuance of
certificate of release to service incl. subcontractor’s release documents.
• Provide copy of each certificate of release to service to aircraft operator,
together with copy of any specific approved repair/modification
• Retain copy’s of all detailed maintenance records + any associated
maintenance data for 3 years from the date the aircraft or component
to which the work relates was released.
1. These Records shall be stored in a manner that ensures protection from
damage, alteration + theft.
2. Computer backup discs, tapes etc. shall be stored:
– in a different location from that containing the working discs, tapes etc.,
– in an environment that ensures they remain in good condition.
Notes
• “Associated maintenance data” = specific info. such as repair + modification data (manuals+SB)
• Maintenance records should refer to the revision status of the data used.
• AMC 145.A.42 (d) clause g. "The following types of components should typically be classified as
unsalvageable: Components for which maintenance records and/or traceability to the
manufacturer can not be retrieved".
GM + AMC 145.A.55
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Part 66 / Part 147
Certifying staff and Training
Part 66 certifying staff

• Privileges
– cat A Line maintenance certifying mechanic
– Cat B1 Maintenance certifying technician – mechanical
– Cat B2 Maintenance certifying technician - avionic
– Cat C Base maintenance certifying engineer
• Type ratings
– Always Required if TO mass above 5700kg
Training per Part 147 required
49
Law and Regulations related to air traffic

Relation between EASA and FAA
•Bilateral J.H.A. van den

agreements Elshout
SPL/CG
•Differences KLM
between EASA
and FAA
50
25
Bilateral agreement USA-EEC (FAA-EASA)
in place since May 1 2011
USA EEC
Department EU Council
of State
+EP
Agreement
FAA (BOB) EC (BOB)
Annexes
FAA EASA
Technical Implementation Procedures
Maintenance annex guidance
51
The construction of the USA-EEC BASA - Responsibilities
Responsible (U.S.) Responsible (EU)
Executive Implementing measures:

Agreement •EASA or Commission
Department of State and FAA Modifications:
Attachment 1 •Council and Parliament
( BASA)
Annex 1 Annex 2 Initial:
Airworthiness Maintenance •Council + Parliament
Department of State and 4 Appendices
FAA Appendix Modifications:
•Commission
New Annexes
•Council
Technical Implementation Maintenance Annex

Procedures for Airworthiness Guidance (MAG)
FAA and Environmental EASA
Certification (TIP)
5 Appendices 4 Appendices
COB + JCMB
52
26
BASA FAA EASA effective May 1 2011
Specifics of agreement:
• reciprocal acceptance of safety findings in 14 EEC countries
and USA
– design
– Aircraft and part manufacturing
– continued airworthiness
– repair station oversight
• Future US acceptance of EEC aeronautical products from all
member states, beyond current 14 with individual agreements with
US
• Bilateral oversight board to manage implementation
http://easa.europa.eu/rulemaking/international-cooperation-bilateral-agreements.php
53
Implementation procedures design + production

.POST DESIGN APPROVALS Covered by Technical Implementation
Procedures (TIP R3)
• FAA Major non critical repair design data accepted by EASA if
– FAA is authority of State of Design
– FAA repair design data approval through one of following options
• FAA letter,
• FAA Form 8110- 3, FAA Form 8100-9,
• FAA Form 337 or a
• Signed cover page of a repair specification (RS DER)
• FAA minor
– EASA accepts data used in support of minor repairs when:
• EASA has certificated/validated the product or appliance, and
• the FAA is authority of State of Design for the repair design data, and
• the repair design data has been provided by a U.S. TC, STC or TSOA
holder, or
• for minor repairs from other than a U.S. TC / STC or TSOA holder, the
determination that data are acceptable (under 14 CFR Part 43) has been
made by a U.S. maintenance organization under FAA’s authorized system.
Note:
Unless minor repair data was previously used to repair an N-registered
aircraft, an EU company cannot determine any data to be acceptable data
under 14 CFR Part 43 for use on an EU-registered aircraft
– An EU company must use EASA Part 21 for approval of repair data for use on an EU-registered aircraft.
54
27
FAA USA
Differences FAA versus EASA
55
Differences FAA versus EASA
• FAA121 (big USA operators) is comparable to EASA Part M +

FAA minor design approvals
– all design in EASA is limited to part 21
• Difference in Major / minor definition resulting in certain FAA
majors classified as EASA minor
• individual DER (Designated Engineering Representatives)
acting for FAA process design approval.
– In EASA this requires an EASA Design Organisation (DOA)
• All EASA design changes (incl repair appr.) require part 21 approval
– FAA DER is not allowed to approve FAA-minors
– FAA minor repairs designs are handled by part 43
• System for part approvals of alternative parts “FAA PMA”
versus the European EPA option through a DOA and POA
56
28
FAA PMA versus EASA EPA
Differences J.H.A. van den

between EASA Elshout
and FAA SPL/CG
KLM
PMA = Part
Manufacturing
approval
57
Part manufacturing
FAA PMA versus EASA EPA
FAA PMA EASA EPA
PMA – Part Manufacturing EPA EASA Part Approval
Approval
• Production + design approval (one • Production approval for a part
document) designed by EASA DOA
• Approved direct by FAA • No direct EASA part approval
• Published through FAA records • No publication by EASA
• Production by PMA holder • Production by EASA POA or
EASA 145 repair station
Note: Note:
• EASA acceptance by bilateral for • separate FAA acceptance of
US products except critical parts design and production by
bilateral
58
29
Airworthiness Regulation Links
EASA
• regulation structure
– http://easa.europa.eu/regulations/regulations-structure.php
• Certification specs
– http://easa.europa.eu/agency-measures/certification-
specifications.php
• Bilaterals
– http://easa.europa.eu/rulemaking/international-cooperation-
bilateral-agreements.php
FAA
• Code of regulations
– http://www.ecfr.gov/cgi-bin/text-
idx?c=ecfr&tpl=/ecfrbrowse/Title14/14tab_02.tpl
59
Acronyms 1
• AD: Airworthiness Directive
• AGM: Advisor & Guidance Material
• AMP: Aircraft Maintenance Program
• AMC: Acceptable Means of Compliance
• AMO: Approved Maintenance Organisation
• ATC: Air Traffic Control
• ATM : Authorization Training Manual
• BOB: Bilateral oversight board
• CAME: Continuous Airworthiness Management Exposition
• CAMO:Continuous Airworthiness Management Organisation
• CFR: Code of Federal Regulations
• COB: Certification Oversight Board
• CS: Certification specification
• CSM: Customer Support Manual
• DOE: Design Organisation Exposition
• EASA: European Aviation Safety Agency
• ED: Easa Decision
60
30
Acronyms 2
• EPA: European Part Approval
• ETSO: European Technical Standard Order
• GMM: General Maintenance Manual
• JCMB: Joint Maintenance Coördinaten Board
• IATA: International Air Transport Association
• ICA: Instructions for Continued Airworthiness
• IEM: Interpretative / Explanatory Material
• ICAO: International Civil Aviation Organisation
• MOE: Maintenance Organisation Exposition
• MRI: Maintenance Required Item
• NAA: National Aviation Authority
• NPA: Notice of Proposed Amendment
• NPRM: Notice of Proposed Rule Making
• OEM: Original Equipment Manufacturer
• SB: Service Bulletin
• SMS: Safety Management System
• TCDS: Type Certificate Data Sheet
61
31

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EASA Regulatory structure

Design and maintenance related to airworthiness

Gorham J.H.A. van den

• These slides are for training purposes only and are a

• Regulating bodies / jurisdictions:

Aviation is an international Industry and requires an

National Aviation regulating jurisdictions

Note: Bilateral agreements exist between governments / states

Relation EASA parts

Reg 748/2012 Regulation

EASA regulation structure airworthiness 2014

EASA EASA decisions internal

•Commission J.H.A. van den

Initial Airworthiness = Design + production Part 21

CS-22 Sailplanes and Powered Sailplanes

EASA Design approvals Part 21

Approval of a design, repair or change requires:

TC Type Design Part 21 Subpart B

The “Type Certificate” includes

The aircraft TCDS includes noise

TC holder is responsible for the type design of complete product

TC holder has to publish

Supplemental type certificate (STC)

System for major changes

DOA: RELATIONSHIPS BETWEEN DESIGN, DAS

Subpart J DAS GM 1 to 21.A.239(a)

Compliance of parts + appliances

Classification of changes + repairs PART 21

Risk assessment during design

Critical parts PART21

Repairs to engine or APU critical parts would normally only be

Appreciable effect to: Yes

•Adjustment of certification basis,

Repair Part 21 Subpart M 21A.431

Elimination of damage and/or restoration to airworthy condition

Parts + appliances to be used for the repair shall be

• under Subpart F (production without POA);

Production Organisational Approval (POA)

Part 21 Subpart F Production without POA when

Specified by an approved design

“officially recognized Standards”

e.g.: NAS, AMS etc.

European Technical Standard Order (ETSO)

Article produced in accordance with approved design data

• Holders of repair or change design approvals (DOA,

Airworthiness directives Parts 21 21A.3B

Issued or adopted by the Agency which mandates actions to be

When authority of a (EASA) Member State receives an

Issued to aircraft that

instructions for continued airworthiness

Publication requirement ICA for Holder of TC (21.A.61) and

Continuing Airworthiness PART M/145/66/147

Continuing Airworthiness Part M

Requirements for air operations :

• Occurrence reporting system

2042/2003 ANNEX I (Part-M) M.A.201

The aircraft maintenance programme must establish

Component status part 145

Part 145 maintenance records