CRD 2014-04

European Aviation Safety Agency
Comment-Response Document 2014-04
Appendix 1
to Opinion No 13/2016
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An agency of the European Union
European Aviation Safety Agency Appendix 1 to Opinion No 13/2016 — CRD to NPA 2014-04
Table of contents
Table of contents
1. Procedural information .................................................................................................................................... 3

1.1. The rule development procedure..............................................................................................................3
1.2. The structure of this CRD and related documents ....................................................................................3
1.3. The next steps in the procedure ................................................................................................................3
2. Summary of comments and responses ............................................................................................................ 5
3. Draft AMC/GM (draft EASA Decision) .............................................................................................................. 6
3.1. AMC/GM to Part-M ...................................................................................................................................6
3.2. Draft AMC/GM to Part-145 .....................................................................................................................37
3.3. Draft AMC/GM to Part-CAT .....................................................................................................................38
3.4. Draft AMC/GM to Part-NCC.....................................................................................................................39
3.5. Draft AMC/GM to Part-NCO ....................................................................................................................40
3.6. Draft AMC/GM to Part-SPO .....................................................................................................................40
4. Individual comments ...................................................................................................................................... 41
5. Appendix A — Attachments ......................................................................................................................... 204
1. Procedural information
1.1. The rule development procedure
The European Aviation Safety Agency (EASA) developed this Comment-Response Document (CRD) in
line with Regulation (EC) No 216/20081 (EASA Basic Regulation) and the Rulemaking Procedure2.
This rulemaking activity is included in the EASA 5-year Rulemaking Programme under RMT.0276. The
scope and timescales of the task were defined in the related ToR.
The draft Regulation and the related acceptable means of compliance (AMC)/guidance material (GM)
have been developed by EASA based on the inputs of RG NPA 2014-04 (RMT.0276 (MDM.076)) that
assessed the comments received on NPA 2014-04. 350 comments were received from interested
parties, including aircraft owners, operators, associations, maintenance organisations, CAMOs,
manufacturers, CAs and individuals.
The process map on the title page contains the major milestones of this rulemaking activity.
1.2. The structure of this CRD and related documents

Chapter 1 of this CRD contains the procedural information related to this task. Chapter 3 of the CRD
contains the draft AMC/GM to Annex I (Part-M) and Annex II (Part-145) to Regulation (EU)
No 1321/20143 (the CAW Regulation4), as well as to Annex IV (Part-CAT), Annex VI (Part-NCC),
Annex VII (Part-NCO) and Annex VIII (Part SPO) to Regulation (EU) No 965/20125 (the Air OPS
Regulation6). A summary of the comments received on NPA 2014-04 and the responses thereto are
provided in Chapter 2 of the Explanatory Note (EN) to the related Opinion No 13/20167 (see also
Chapter 2 of the CRD), and the full set of individual comments in Chapter 4 of the CRD.
1.3. The next steps in the procedure

EASA published this CRD concurrently with Opinion No 13/2016, which contains proposed
amendments to the CAW Regulation. Said Opinion is submitted to the European Commission to be
used as technical basis in order to prepare a legislative proposal.
1
Regulation (EC) No 216/2008 of the European Parliament and of the Council of 20 February 2008 on common rules in the field of
civil aviation and establishing a European Aviation Safety Agency, and repealing Council Directive 91/670/EEC, Regulation (EC)
No 1592/2002 and Directive 2004/36/EC (OJ L 79, 19.3.2008, p. 1).
2
EASA is bound to follow a structured rulemaking process as required by Article 52(1) of the Basic Regulation. Such a process has
been adopted by the EASA Management Board (MB) and is referred to as the ‘Rulemaking Procedure’. See MB Decision No 18-2015
of 15 December 2015 replacing Decision 01/2012 concerning the procedure to be applied by the Agency for the issuing of opinions,
certification specifications and guidance material.
3
Commission Regulation (EU) No 1321/2014 of 26 November 2014 on the continuing airworthiness of aircraft and aeronautical
products, parts and appliances, and on the approval of organisations and personnel involved in these tasks (OJ L 362, 17.12.2014, p. 1).
4
Continuing-Airworthiness Regulation.
5
Commission Regulation (EU) No 965/2012 of 5 October 2012 laying down technical requirements and administrative procedures
related to air operations pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council (OJ L 296,
25.10.2012, p. 1).
6
Air Operations Regulation
7
http://easa.europa.eu/document-library/opinions
The ED Decision, to which the related AMC/GM will be annexed, will be published by EASA once the
European Commission has adopted the related Regulation.
2. Summary of comments and responses
2. Summary of comments and responses

A summary of the comments received on NPA 2014-04 and the responses thereto are contained in the
EN to Opinion No 13/2016.
The subjects which received the more significant comments are listed as follows:
— record-keeping period;
— life-limited parts (LLPs) and time-controlled components (TCCs);
— detailed maintenance records;
— information in statuses; and
— general aviation (GA)-related topics.
3. Draft AMC/GM
3. Draft AMC/GM (draft EASA Decision)

3.1. AMC/GM to Part-M
1. ‘CONTENTS’ is replaced by the following:
AMC M.1
SECTION A — TECHNICAL REQUIREMENTS
SUBPART A — GENERAL
SUBPART B — ACCOUNTABILITY
GM M.A.201 Responsibilities
GM M.A.201(e) Responsibilities
AMC M.A.201(e)(2) Responsibilities
GM M.A.201(f) Commercial ATO
AMC M.A.201(h) Responsibilities
GM M.A.201(i), M.A.302(h) and M.A.901(l)
GM M.A.201(i) Responsibilities
AMC M.A.201(i)(3) Responsibilities
AMC M.A.202(a) Occurrence reporting
AMC M.A.202(b) Occurrence reporting
SUBPART C — CONTINUING AIRWORTHINESS

AMC M.A.301(1) Continuing-airworthiness tasks
AMC M.A.302 Aircraft maintenance programme
GM M.A.302(a) Aircraft maintenance programme
AMC M.A.302(d) Aircraft maintenance programme
AMC M.A.302(e) Aircraft maintenance programme
AMC M.A.302(f) Aircraft maintenance programme
AMC M.A.302(h) Aircraft maintenance programme
GM M.A.302(h) Aircraft maintenance programme
AMC M.A.302(i) Aircraft maintenance programme
AMC M.A.304 Data for modifications and repairs
3. Draft AMC/GM
GM M.A.305 Aircraft continuing-airworthiness record system

AMC M.A.305(a) Aircraft continuing-airworthiness record system
AMC M.A.305(b)(1) Aircraft continuing-airworthiness record system
AMC M.A.305(c)(1) Aircraft continuing-airworthiness record system
GM M.A.305(c)(2) Aircraft continuing-airworthiness record system
GM M.A.305(d) Aircraft continuing-airworthiness record system
GM M.A.305(d)(2) Aircraft continuing-airworthiness record system
AMC M.A.305(e) Aircraft continuing-airworthiness record system
GM M.A.305(e) Aircraft continuing-airworthiness record system
AMC M.A.305(e)(1) Aircraft continuing-airworthiness record system
GM M.A.305(e)(3) Aircraft continuing-airworthiness record system
AMC M.A.305(f) Aircraft continuing-airworthiness record system
AMC M.A.306(a) Aircraft technical log system
AMC M.A.306(b) Aircraft technical log system
AMC M.A.307(a) Transfer of aircraft continuing-airworthiness records
SUBPART D — MAINTENANCE STANDARDS

AMC M.A.401(b) Maintenance data
AMC M.A.401(c) Maintenance data
AMC M.A.402(a) Performance of maintenance
GM M.A.402(a) Performance of maintenance
AMC M.A.402(c) Performance of maintenance
AMC M.A.402(d) Performance of maintenance
AMC M.A.402(e) Performance of maintenance
AMC M.A.402(f) Performance of maintenance
AMC M.A.402(g) Performance of maintenance
AMC1 M.A.402(h) Performance of maintenance
AMC2 M.A.402(h) Performance of maintenance
GM M.A.402(h) Performance of maintenance
AMC M.A.403(b) Aircraft defects
AMC M.A.403(d) Aircraft defects
SUBPART E — COMPONENTS
AMC M.A.501(a) Installation
3. Draft AMC/GM
AMC M.A.501(b) Installation

AMC M.A.501(c) Installation
AMC M.A.501(d) Installation
AMC M.A.502 Component maintenance
AMC M.A.502(b) and (c) Component maintenance
GM M.A.503 LLPs and TCCs
AMC M.A.504(a) Control of unserviceable components
AMC M.A.504(b) Control of unserviceable components
AMC M.A.504(c) Control of unserviceable components — unsalvageable components
AMC M.A.504(d)(2) Control of unserviceable components
AMC M.A.504(e) Control of unserviceable components
SUBPART F — MAINTENANCE ORGANISATION

AMC M.A.602 Application
AMC M.A.603(a) Extent of approval
AMC M.A.603(c) Extent of approval
AMC M.A.604 Maintenance organisation manual
AMC M.A.605(a) Facilities
AMC M.A.605(b) Facilities
AMC M.A.605(c) Facilities
AMC M.A.606(a) Personnel requirements
AMC M.A.606(b) Personnel requirements
AMC M.A.606(c) Personnel requirements
AMC M.A.606(d) Personnel requirements
AMC M.A.606(e) Personnel requirements
AMC M.A.606(f) Personnel requirements
AMC M.A.606(h)(2) Personnel requirements
AMC M.A.607 Certifying staff and airworthiness review staff
AMC M.A.607(c) Certifying staff and airworthiness review staff
AMC M.A.608(a) Components, equipment and tools
AMC M.A.608(b) Components, equipment and tools
AMC M.A.609 Maintenance data
AMC M.A.610 Maintenance work orders
AMC M.A.613(a) Component certificate of release to service
AMC M.A.614(a) Maintenance and airworthiness review records
AMC M.A.614(c) Maintenance and airworthiness review records
GM M.A.615 Privileges of the organisation
GM M.A.615(a) Privileges of the organisation
3. Draft AMC/GM
AMC M.A.615(b) Privileges of the organisation

AMC M.A.616 Organisational review
AMC M.A.617 Changes to the approved maintenance organisation
SUBPART G — CONTINUING-AIRWORTHINESS MANAGEMENT ORGANISATION

AMC M.A.702 Application
AMC1 M.A.704 Continuing-airworthiness management exposition
AMC2 M.A.704 Continuing-airworthiness management exposition
AMC M.A.704(a)(2) Continuing-airworthiness management exposition
AMC M.A.705 Facilities
AMC M.A.706 Personnel requirements
AMC M.A.706(a) Personnel requirements
AMC M.A.706(e) Personnel requirements
AMC M.A.706(f) Personnel requirements
AMC M.A.706(i) Personnel requirements
AMC M.A.706(k) Personnel requirements
AMC M.A.707(a) Airworthiness review staff
AMC M.A.707(a)(1) Airworthiness review staff
AMC M.A.707(a)(2) Airworthiness review staff
AMC M.A.707(b) Airworthiness review staff
AMC M.A.707(c) Airworthiness review staff
AMC M.A.707(e) Airworthiness review staff
GM M.A.708 Continuing-airworthiness management
AMC M.A.708(b)(3) Continuing-airworthiness management
GM M.A.708(b)(4) Continuing-airworthiness management
AMC1 M.A.708(c) Continuing-airworthiness management
AMC2 M.A.708(c) Continuing-airworthiness management
GM M.A.708(c) Continuing-airworthiness management
AMC M.A.708(d) Continuing-airworthiness management
AMC M.A.709 Documentation
GM M.A.709 Documentation
GM M.A.710 Airworthiness review
AMC M.A.710(a) Airworthiness review
AMC M.A.710(b) and (c) Airworthiness review
AMC M.A.710(d) Airworthiness review
AMC M.A.710(e) Airworthiness review
AMC M.A.710(ga) Airworthiness review
GM M.A.710(h) Airworthiness review
3. Draft AMC/GM
AMC M.A.711(a)(3) Privileges of the organisation

AMC M.A.711(b) Privileges of the organisation
AMC M.A.711(c) Privileges of the organisation
AMC M.A.712(a) Quality system
AMC M.A.712(b) Quality System
AMC M.A.712(f) Quality system
AMC M.A.713 Changes to the approved continuing-airworthiness organisation
AMC M.A.714 Record-keeping
SUBPART H — CERTIFICATE OF RELEASE TO SERVICE (CRS)

AMC M.A.801 Aircraft certificate of release to service after embodiment of a Standard Change or a
Standard Repair (SC/SR)
AMC M.A.801(b) Aircraft certificate of release to service
AMC M.A.801(d) Aircraft certificate of release to service
AMC M.A.801(f) Aircraft certificate of release to service
AMC M.A.801(g) Aircraft certificate of release to service
AMC M.A.801(h) Aircraft certificate of release to service
AMC M.A.802 Component certificate of release to service
AMC M.A.803 Pilot-owner authorisation
SUBPART I — AIRWORTHINESS REVIEW CERTIFICATE

AMC M.A.901 Aircraft airworthiness review
AMC M.A.901(a) Aircraft airworthiness review
AMC M.A.901(b) Aircraft airworthiness review
AMC M.A.901(c)(2), (e)(2) and (f) Aircraft airworthiness review
AMC M.A.901(d) and (g) Aircraft airworthiness review
AMC M.A.901(g) Aircraft airworthiness review
AMC M.A.901(j) Aircraft airworthiness review
AMC M.A.901(l)(1) Aircraft airworthiness review
GM M.A.901(l)(5) Aircraft airworthiness review
GM M.A.901(l)(7) Aircraft airworthiness review
AMC M.A.903(a)(1) Transfer of aircraft registration within the EU
AMC M.A.903(b) Transfer of aircraft registration within the EU
AMC M.A.904(a)(1) Airworthiness reviews of aircraft imported into the EU
AMC M.A.904(a)(2) Airworthiness reviews of aircraft imported into the EU
AMC M.A.904(b) Airworthiness review of aircraft imported into the EU
3. Draft AMC/GM
SECTION B — PROCEDURE FOR COMPETENT AUTHORITIES
SUBPART A — GENERAL
AMC M.B.102(a) Competent authority — General
AMC1 M.B.102(c) Competent authority — Qualification and training
AMC2 M.B.102(c) Competent authority — Qualification and training
AMC M.B.102(d) Competent authority organisation — Procedures
AMC M.B.104(a) Record-keeping
AMC M.B.104(f) Record-keeping
AMC M.B.105(a) Mutual exchange of information
SUBPART B — ACCOUNTABILITY
SUBPART C — CONTINUING AIRWORTHINESS

AMC M.B.301(a) Maintenance programme
AMC M.B.301(b) Maintenance programme
AMC M.B.301(c) Maintenance programme
AMC M.B.301(d) Maintenance programme
AMC1 M.B.303(a) Aircraft continuing-airworthiness monitoring
AMC2 M.B.303(a) Aircraft continuing-airworthiness monitoring
GM M.B.303(a) Aircraft continuing-airworthiness monitoring
AMC1 M.B.303(b) Aircraft continuing-airworthiness monitoring
GM M.B.303(b) Aircraft continuing-airworthiness monitoring
AMC M.B.303(d) Aircraft continuing-airworthiness monitoring
SUBPART D — MAINTENANCE STANDARDS
SUBPART E — COMPONENTS
SUBPART F — MAINTENANCE ORGANISATION

AMC M.B.602(a) Initial approval
AMC M.B.602(b) Initial approval
AMC M.B.602(c) Initial approval
AMC M.B.602(e) Initial approval
AMC M.B.602(f) Initial approval
AMC M.B.602(g) Initial approval
AMC M.B.603(a) Issue of approval
AMC M.B.603(c) Issue of approval
3. Draft AMC/GM
AMC M.B.604(b) Continuing oversight

AMC M.B.605(a)(1) Findings
AMC M.B.606 Changes
SUBPART G — CONTINUING-AIRWORTHINESS MANAGEMENT ORGANISATION

AMC M.B.701(a) Application
AMC M.B.702(a) Initial approval
AMC M.B.702(b) Initial approval
AMC M.B.702(c) Initial approval
AMC M.B.702(e) Initial approval
AMC M.B.702(f) Initial approval
AMC M.B.702(g) Initial approval
AMC M.B.703 Issue of approval
AMC M.B.703(a) Issue of approval
AMC M.B.703(c) Issue of approval
AMC M.B.704(b) Continuing oversight
AMC M.B.705(a)(1) Findings
AMC M.B.706 Changes
SUBPART H — CERTIFICATE OF RELEASE TO SERVICE (CRS)
SUBPART I — AIRWORTHINESS REVIEW CERTIFICATE

AMC M.B.901 Assessment of recommendations
AMC M.B.902(b) Airworthiness review by the competent authority
AMC M.B.902(b)(1) Airworthiness review by the competent authority
AMC M.B.902(b)(2) Airworthiness review by the competent authority
AMC M.B.902(c) Airworthiness review by the competent authority
AMC AND GM TO THE APPENDICES TO PART-M

GM to Appendix I Continuing-airworthiness management contract
AMC to Appendix II to Part-M Use of the EASA Form 1 for maintenance
GM to Appendix II to Part-M Use of the EASA Form 1 for maintenance
AMC to Appendix V to Part-M Maintenance organisation approval referred to in Annex I (Part-M)
Subpart F
AMC to Appendix VI to Part-M Continuing-airworthiness management organisation approval referred
to in Annex I (Part-M) Subpart G
AMC to Appendix VII Complex maintenance tasks
AMC to Appendix VIII Limited pilot-owner maintenance
3. Draft AMC/GM
APPENDICES TO THE AMC AND GM

Appendix I to AMC M.A.302 and AMC M.B.301(b) Content of the maintenance programme
Appendix II to AMC M.A.711(a)(3) Subcontracting of continuing-airworthiness management tasks
Appendix III to GM M.B.303(b) Key risk elements
Appendix IV to AMC M.A.604 Maintenance organisation manual
Appendix V to AMC M.A.704 Continuing-airworthiness management exposition
Appendix VI to AMC M.B.602(f) EASA Form 6F
Appendix VII to AMC M.B.702(f) EASA Form 13
Appendix VIII to AMC M.A.616 Organisational review
Appendix IX to AMC M.A.602 and AMC M.A.702 EASA Form 2
Appendix X to AMC M.B.602(a) and AMC M.B.702(a) EASA Form 4
Appendix XI to AMC M.A.708(c) Contracted maintenance
Appendix XII to AMC M.A.706(f) and AMC1 M.B.102(c) Fuel tank safety training
Appendix XIII to AMC M.A.712(f) Organisational review
2. New GM M.A.305 is added
GM M.A.305 Aircraft continuing-airworthiness record system

(a) The aircraft continuing-airworthiness records are the means to assess the airworthiness status of
a product and its components. An aircraft continuing-airworthiness record system includes the
processes to keep and manage those records and should be proportionate to the subject
aircraft. Aircraft continuing-airworthiness records should provide the owner/CAMO of an aircraft
with the information needed:
(1) to demonstrate that the aircraft is in compliance with the applicable airworthiness
requirements; and
(2) to schedule all future maintenance as required by the AMP, based on the last
accomplishment of the specific maintenance, if any, as recorded in the aircraft continuing-
airworthiness records.
(b) ‘Applicable airworthiness limitation parameter’ and ‘applicable parameter’ mean ‘flight hours’
and/or ‘flight cycles’ and/or ‘landings’ and/or ‘calendar time’, and/or any other applicable
utilisation measurement unit, as appropriate.
(c) An LLP is a part for which the maintenance schedule of the AMP requires the permanent
removal from service when or before the specified mandatory life limitation in accordance with
Regulation (EU) No 748/2012 in any of the applicable parameters is reached.
(d) The ‘current status of LLPs’ should indicate for each affected part the life limitation, the total life
accumulated in any applicable parameter (as appropriate), and the remaining life in any
applicable parameter before the life limitation is reached.
(e) The term ‘TCCs’ embraces any component for which the maintenance schedule of the AMP
requires periodically the removal for maintenance to be performed in an appropriate approved
3. Draft AMC/GM
organisation for maintenance of components (workshop) to return the component to a specified

standard, to replace any sub-component of the assembly by new ones, or to inspect/test the
component’s performance after a service period controlled at component level in accordance
with the specified airworthiness limitation, defined as per Regulation (EU) No 784/2012, in any
of the applicable parameters.
(f) The term ‘current status of time-controlled components’ means the current status of compliance
with the required periodic maintenance task(s) from the maintenance schedule of the AMP
specific to the time-controlled components. It should include the life accumulated by the
affected components in the applicable parameter, as appropriate, since the last accomplishment
of scheduled maintenance specified in the maintenance schedule of the AMP. Any action that
alters the periodicity of the maintenance task(s) or changes the parameter of this periodicity
should be recorded.
(g) ‘Detailed maintenance records’ refers to those records required to be kept by the person or
organisation responsible for the aircraft continuing airworthiness in accordance with M.A.201 in
order for them to be able to fulfil their obligations under Part-M.
These are only a part of the detailed maintenance records required to be kept by a maintenance
organisation under M.A.614 or 145.A.55(c). Maintenance organisations are required to retain all
detailed records to demonstrate that they worked in compliance with the respective
requirements and quality procedures.
All records do not need to be transferred from the maintenance organisation to the person or
organisation responsible for the aircraft continuing airworthiness in accordance with M.A.201
unless they specifically contain information relevant to aircraft configuration and future
maintenance. Thus, incoming certificates of conformity, batch number references and individual
task card sign-offs verified by and/or generated by the maintenance organisation are not
required to be retained by the person or organisation responsible in accordance with M.A.201.
However, dimensional information contained in the task card sign-off or work package may be
requested by the owner/CAMO in order to verify and demonstrate the effectiveness of the AMP.
Information relevant to future maintenance may be contained in specific documents related to:
— modifications;
— airworthiness directives;
— repaired and non-repaired damage;
— components referred to in M.A.305(d); and
— measurements associated with defects.
(h) An airworthiness limitation is a boundary beyond which an aircraft or a component thereof is
not to be operated unless the instructions associated with this airworthiness limitation are
complied with.
(i) ‘Other maintenance required for continuing airworthiness’ means unscheduled or out of phase
maintenance due to abnormal or particular conditions or events which have an impact on the
continuing airworthiness of the aircraft at the time of its return to service. It is not intended to
request every single condition described in the maintenance data, e.g. Chapter 5 of the Aircraft
3. Draft AMC/GM
Maintenance Manual (AMM), but just those conditions that cannot be captured by other means,
i.e. for the case where the maintenance related to the event is not included in the records for
repairs. Some abnormal or particular conditions or events that may be kept under this
requirement are lightning strikes, hard landings, long-term storage, propeller or rotor overspeed,
overtorque, impact on a main rotor blade, etc.
(j) The term ‘in-service history records’ embraces records by which the current status of LLPs is
determined. The ‘in-service history records’ template may be adjusted to the relevant
characteristics of the LLP, e.g. an engine disk being different from a fire extinguisher squib or
landing gear sliding tube.
Such records document an LLP each time it enters service or is removed from service. They
should clearly:
(1) identify the part by its part number and serial number;
(2) show the date of installation and removal (i.e. date on/date off);
(3) show the details of the installation and removal (i.e. type, serial number, weight variant,
thrust rating, as appropriate, of the aircraft, engine, engine module, or propeller) at
installation and removal of the part when this is necessary to appropriately control the life
limitation; and
(4) show the total in-service life accumulated in any applicable parameter, as appropriate,
corresponding to the dates of installation and removal of the part.
Any other events that may affect the life limitation or change the limitation parameter, such as
an embodied modification (in accordance with ADs, service bulletins or any product
improvements) should also be included in the in-service history record. Not all modifications are
necessarily pertinent to the life limitation of the component. Additionally, if a parameter is not
relevant to the life of the part, then this parameter does not need to be recorded.
(k) The term ‘permanently withdrawn from service’ means for an aircraft or component to be
moved to a location that is not used for storage and/or future return to service.
(l) The term ‘current status’ means the data which accurately establishes the level of compliance of
an aircraft, engine, propeller or component thereof with a requirement. Each ‘current status’
should:
(1) identify the aircraft, engine, propeller or component it applies to;
(2) be dated, and
(3) include the relevant total in-service life accumulated in the applicable parameter on the
date of the status.
3. Draft AMC/GM
3. New AMC M.A.305(a) is added as follows:
AMC M.A.305(a) Aircraft continuing-airworthiness record system

(a) The inclusion of the CRS in the aircraft continuing-airworthiness record system means that the
date at which the maintenance was performed, and/or that any applicable parameter, including
a unique reference to the CRS, should be processed in the record system.
(b) For components with airworthiness limitations, this information should be found on the
authorised release certificate (EASA Form 1 or equivalent). For LLPs, some relevant information
required by M.A.305 may need to be introduced into the in-service history records.
4. New AMC M.A.305(b)(1) is added as follows:
AMC M.A.305(b)(1) Aircraft continuing-airworthiness record system

(a) Certain gas turbine engines and propellers are assembled from modules, and a record of the
total life accumulated in service for the complete engine or propeller may not be kept. When
owners and operators wish to take advantage of the modular design, then the total life
accumulated in service for each module, as well as in-service history, if applicable, and detailed
maintenance records for each module, should be maintained. The continuing-airworthiness
records, as specified, should be kept with the module and show compliance with any mandatory
requirements pertaining to that module.
(b) The recording of in-service life accumulation may be necessary also in other measurement units
to ensure the continuing airworthiness of the aircraft. For example, a mandatory life limitation
measured in cycles of auxiliary power unit (APU) usage may apply to some rotating parts. In such
a case, APU cycles need to be recorded.
5. New AMC M.A.305(c)(1) is added as follows:

(a) The current status of ADs, and measures mandated by the competent authority in immediate
reaction to a safety problem, should identify the product/component, the applicable ADs,
including revision or amendment numbers, and the date on which the status was updated. For
the purpose of assessing the AD status, there is no need to list those ADs that are superseded or
cancelled.
(b) If the AD is generally applicable to the aircraft or component type but is not applicable to the
particular aircraft, engine, propeller or component, then this should be identified as well as the
reason why it is not applicable.
(c) The current status of ADs should include the CRS date on which the AD or measure was
accomplished (the date the CRS was issued), and where the AD or measure is controlled by flight
hours and/or flight cycles and/or landings and/or any other applicable parameter, as
appropriate, it should include the corresponding total life accumulated in service in that
parameter on the date when the AD or measure was accomplished and/or the due limit in the
3. Draft AMC/GM
appropriate parameter. For repetitive ADs or measures, only the last and next applications with
the reference to the applicable parameter should be recorded in the current status.
(d) The current status of ADs should also specify the method of compliance with the ADs, and which
part of a multipart AD or measure has been accomplished, where a choice is available in the AD
or measure.
(e) The current status of ADs should be sufficiently detailed to identify any loadable software
aircraft part (LSAP) used for operating or controlling the aircraft.
(f) When the AD is multipart or requests assessments of certain inspections, this information should
be included as well.
6. New AMC M.A.305(c)(2) is added as follows:

(a) ‘Status of current modifications and repairs’ means a list, compiled at aircraft level, of
modifications and repairs currently embodied. It should include the identification of the aircraft,
engine(s) or propeller(s), as appropriate, and the date of the CRS when the modification or
repair was accomplished. Where a modification or repair creates the need for the
accomplishment of scheduled maintenance tasks, the reference to the applicable tasks should
be added to the AMP. The status should include the reference to the data in accordance with
M.A.304, which provides the accomplishment procedure for the modification or repair. It should
also specify which part of a multipart modification or repair has been accomplished, as well as
the method of compliance, where a choice is available in the data.
(b) In addition to the previous applicable information, with respect to structure, the status of the
current repairs should contain the description of the repair (e.g. doubler, blend, crack, dent,
etc.), its location (e.g. reference to stringers, frames, etc.) and its dimensions. In the case of
blend-out repairs, the remaining material should be recorded as well.
(c) The status of modifications should be sufficiently detailed to identify any installed loadable
software aircraft part (LSAP) used for operating or controlling the aircraft, the part number of
which evolves independently of its associated aircraft hardware component, as identified in the
maintenance data of the relevant design approval holders (DAHs).
Other loadable software parts, such as navigational databases or entertainment systems, are not
considered under this recording requirement.
(d) For the purpose of this AMC, a component replaced by a fully interchangeable alternate
component is not considered a modification if this condition is published by the DAH.
(e) The status of modifications and repairs should include engine(s), propeller(s) and components,
subject to mandatory instructions and associated airworthiness limitations, and it is not
intended to be retained for other components.
3. Draft AMC/GM
7. New GM M.A.305(c)(2) is added as follows:
GM M.A.305(c)(2) Aircraft continuing-airworthiness record system

(a) The status of modifications and repairs may include the impact of a specific modification or
repair on:
(1) embodiment instructions;
(2) mass and balance change data;
(3) maintenance and repair manual supplements;
(4) maintenance programme and instructions for continuing airworthiness; and/or
(5) aircraft flight manual (AFM) supplements.
(b) When aircraft require a specific loadable software aircraft part (LSAP) configuration in order to
operate correctly, a specific listing with this information may be necessary as well.
8. AMC M.A.305(c)(3) is added as follows:

(a) The ‘current status of compliance with the AMP’ means the last and next accomplishment data
(referring to the applicable parameter) for the tasks specified in the maintenance schedule of
the AMP. It should include:
(1) an identifier specific enough to allow an easy and accurate identification of the task to be
carried out, such as a task reference combined with a task title or short description of the
work to be performed;
(2) the engine, propeller or component identification when the task is controlled at engine,
propeller, or component level; and
(3) the date when the task was accomplished (i.e. the date the CRS was issued), and for
repetitive tasks, when it is next due time, as well as when the terminating action should be
performed.
(b) Where the task is controlled by flight hours and/or flight cycles and/or landings and/or calendar
time and/or any other applicable parameter, the total in-service life accumulated by the aircraft,
engine, propeller or component, as appropriate, in the suitable parameter(s) should also be
included.
9. AMC M.A.305(d) is deleted:
AMC M.A.305(d) Aircraft continuing airworthiness record system

The current status of AD should identify the applicable AD including revision or amendment numbers.
Where an AD is generally applicable to the aircraft or component type but is not applicable to the
particular aircraft or component, then this should be identified. The AD status includes the date when
the AD was accomplished, and where the AD is controlled by flight hours or flight cycles it should
include the aircraft or engine or component total flight hours or cycles, as appropriate. For repetitive
3. Draft AMC/GM
ADs, only the last application should be recorded in the AD status. The status should also specify which
part of a multi-part directive has been accomplished and the method, where a choice is available in the
AD.
The status of current modification and repairs means a list of embodied modification and repairs
together with the substantiating data supporting compliance with the airworthiness requirements. This
can be in the form of a Supplemental Type Certificate (STC), SB, Structural Repair Manual (SRM) or
similar approved document.
The substantiating data may include:
(a) compliance programme; and
(b) master drawing or drawing list, production drawings, and installation instructions; and
(c) engineering reports (static strength, fatigue, damage tolerance, fault analysis, etc.); and
(d) ground and flight test programme and results; and
(e) mass and balance change data; and
(f) maintenance and repair manual supplements; and
(g) maintenance programme changes and instructions for continuing airworthiness; and
(h) aircraft flight manual supplement.
Some gas turbine engines are assembled from modules and a true total time in service for a total
engine is not kept. When owners and operators wish to take advantage of the modular design, then
total time in service and maintenance records for each module is to be maintained. The continuing
airworthiness records as specified are to be kept with the module and should show compliance with
any mandatory requirements pertaining to that module
10. AMC M.A.305(d)(4) and AMC M.A.305(h) is deleted:
AMC M.A.305(d)(4) and AMC M.A.305(h) Aircraft continuing airworthiness record system
The term ‘service life-limited components’ embraces: (i) components subject to a certified life limit
after which the components should be retired, and (ii) components subject to a service life limit after
which the components should undergo maintenance to restore their serviceability.
The current status of service life-limited aircraft components should indicate:
(i) for components subject to a certified life limit: the component life limitation, total number of
hours, accumulated cycles or calendar time and the number of hours/cycles/time remaining
before the required retirement time of the component is reached;
(ii) for components subject to a service life limit: the component service life limit, the hours, cycles
or calendar time since the component has been restored back to their service life and the
remaining service (hours, cycles, calendar time) life before the components need to undergo
maintenance.
Any action that alters the components’ life limit (certified or service) or changes the parameter of the
life limit (certified or service) should be recorded.
3. Draft AMC/GM
When the determination of the remaining life requires knowledge of the different types of
aircraft/engine on which the component has previously been installed, the status of all service-life
limited aircraft components should additionally include a full installation history indicating the number
of hours, cycles or calendar time relevant to each installation on these different types of
aircraft/engine. The indication of the type of aircraft/engine should be sufficiently detailed with regard
to the required determination of remaining life.
Recommendations from the type certificate holder on the procedures to record the remaining life may
be considered.
11. New GM M.A.305(d) is added as follows:
GM M.A.305(d) Aircraft continuing-airworthiness record system

(a) A part is to be considered as an LLP and a TCC when it complies with both definitions given in
GM M.A.305(c) and (e).
For example, the maintenance schedule of the AMP may include both a mandatory permanent
removal for a landing gear sliding tube and a periodic removal for overhaul of the landing gear
(including the sliding tube).
(b) The following table provides a summary of the record-keeping requirements related to LLPs and
TCCs:
Maintenance task from the maintenance Type of component Continuing-airworthiness

schedule of the AMP records
LLP — Current status (M.A.305(d)(1));

e.g.: engine high — In-service history record
pressure turbine (HPT) (M.A.305(e)(3)(i));
disc, landing gear — EASA Form 1 and detailed
sliding tube maintenance records for last
scheduled maintenance and
Permanent removal
subsequent unscheduled
(replacement)
maintenance
Mandatory (M.A.305(e)(3)(ii)); and
instructions — EASA Form 1 and detailed
(and associated maintenance records for
airworthiness modifications and repairs
limitation) in (M.A.305(e)(2)(ii)).
accordance with
Part-21 TCC — Current status
affecting a Periodic removal for
(M.A.305(d)(2));
component maintenance in an e.g.: horizontal
appropriate approved stabiliser actuator, — EASA Form 1 and detailed
workshop, e.g.: landing gear gearbox maintenance records for last
scheduled maintenance and
— overhaul of
subsequent unscheduled
horizontal stabilizer
maintenance
actuator or of a
(M.A.305(e)(3)(ii)); and
landing gear; and/or
— EASA Form 1 and detailed
— replacement of U-
maintenance records for
joints (of a gearbox).
modifications and repairs
3. Draft AMC/GM
(M.A.305(e)(2)(ii)).
12. New GM M.A.305(d)(2) is added as follows:
GM M.A.305(d)(2) Aircraft continuing-airworthiness record system

(a) The maintenance schedule of the AMP may include tasks controlled at component level
stemmimg from a mandatory requirement in accordance with Part-21, and to be performed in a
workshop, such as:
(1) the removal of a component for periodic restoration in order to return the component to
a specified standard (e.g. removal of landing gear for overhaul);
(2) the periodic removal of a component for replacement of a subcomponent by a new one
when it is not possible to restore the item to a specific standard of failure resistance (e.g.
discarding of universal joints of a gearbox, batteries of the escape slide/raft, cartridges of
fire extinguishers, etc.); and
(3) a periodic inspection or test to confirm that a component meets specified performance
standards (e.g. functional check of the portable emergency locator transmitter (ELT), etc.);
the component is left in service (no further maintenance action to be taken) on the
condition that it continues to fulfil its intended purpose within specified performance
limits until the next scheduled inspection.
The above tasks apply to TCCs, as defined in GM M.A.305(e). If a component affected by a task in
accordance with (2) and (3) above is controlled at aircraft level by the AMP, and it has not been
removed since the task was last accomplished, then its status of compliance with M.A.305(d)2 is
already demonstrated by the aircraft records.
Note: the maintenance in accordance with:
— (1) and (2) above assumes a predictable deterioration of the component: the overall
reliability invariably decreases with age; and
— (3) above assumes a gradual deterioration of the component: failure resistance may
reduce and fall below a defined level.
(b) When a component is affected by a maintenance task contained in the AMP, recommended by
the design approval holder (DAH), and controlled at component level, although such component
does not qualify as TCC, the status of the component may need to show that all the maintenance
due on the aircraft according to the AMP has been carried out. There is no specific requirement
to keep the EASA Form 1 or equivalent or any other detailed maintenance records.
(c) For AMPs developed under a methodology oriented towards primary maintenance processes
(e.g. Maintenance Steering Group), the term ‘TCC’ pertains to ‘Hard time’ and ‘On-condition’.
The primary maintenance processes are:
(1) Hard time
This is a preventive process in the context of which known deterioration of a component is
limited to an acceptable level by maintenance actions carried out at periods related to
3. Draft AMC/GM
time in service (e.g. calendar time, number of cycles, number of landings). The prescribed
actions restore the component utility margin to the applicable time limitation.
(2) On-condition
It is a preventive process in the context of which the component is inspected or tested at
specified periods to an appropriate standard in order to determine whether it may
continue in service. The purpose is to remove the component before its failure in service.
(3) Condition monitoring
This is a process in the context of which a condition parameter of a component (vibration,
temperature, oil consumption, etc.) is monitored in order to identify the development of a
fault. The purpose is to remove the component before its failure in service (e.g. due to
related repair costs); however, those components are permitted to remain in service
without preventive maintenance until a functional failure occurs.
Note: for components that are not subject to any of these primary maintenance processes,
corrective maintenance is carried out after failure detection and is aimed at restoring
components to a condition in which they can perform their intended function (‘fly-to-failure’).
(d) The following table provides a summary of the record-keeping requirements related to
components subjected to primary maintenance processes, including components without an
EASA Form 1 in accordance with 21.A.307(c):
Primary maintenance process Continuing-airworthiness records
LLP — Current status (M.A.305(d)(1));

— In-service history record (M.A.305(e)(3)(i));
— EASA Form 1 and detailed maintenance
records for the last scheduled maintenance
and subsequent unscheduled maintenance
(M.A.305(e)(3)(ii)), including modifications
and repairs (M.A.305(e)(2)(ii)).
Hard time — Current status (M.A.305(d)(2));

— EASA Form 1 and detailed maintenance
(M.A.305(e)(3)(ii)), including modifications
and repairs (M.A.305(e)(2)(ii)).
On-condition — Current status (M.A.305(d)(2)); and

TCC — EASA Form 1 and detailed maintenance
(M.A.305(e)(3)(ii)).
If the task is controlled at aircraft level, the
above information may be already contained in
the records related to the AMP (M.A.305(c)(3)
and M.A.305(e)(2)(iii)). If the maintenance was
performed off-wing, EASA Form 1 needs to be
kept.
3. Draft AMC/GM
Condition monitoring EASA Form 1 does not need to be kept unless

this is the means to fulfil another requirement,
for example an AD compliance.
ELA2 aircraft: any component fitted without an The CRS and owner’s acceptance statement
EASA Form 1 in accordance with 21.A.307(c) (M.A.305(e)(3)(iii)).
13. New AMC M.A.305(e) is added as follows:
AMC M.A.305(e) Aircraft continuing-airworthiness record system

(a) The information that constitutes the aircraft continuing-airworthiness records may be entered in
an information technology (IT) system and/or documents equivalent in scope and detail.
IT systems acceptable for supporting the aircraft continuing-airworthiness records should:
(1) include functions so that search of data and production of status is possible;
(2) allow a transfer of the aircraft continuing-airworthiness records data from one system to
another using an industry-wide/worldwide data format or allow printing information;
(3) contain safeguards which prevent unauthorised personnel from altering data; and
(4) ensure the integrity of the data, including traceability of amendments.
(b) ‘Documents equivalent in scope and detail’ are included in the airworthiness record system and
may be an aircraft logbook, engine logbook(s) or engine module log cards, propeller logbook(s)
and log cards for LLPs.
Any logbook/log card should contain:
(1) identification of the product or component it refers to;
(2) type, part number, serial number and registration, as appropriate, of the aircraft, engine,
propeller, engine module, or component to which the component has been fitted, along
with the reference to the installation and removal;
(3) the date and the corresponding total in-service life accumulated in any applicable
parameter, as appropriate; and
(4) any AD, modification, repair, maintenance or deferred maintenance tasks applicable.
If fulfilling the applicable requirements, a logbook/log card as described above is a means to
comply with the current status and in-service history record for each LLP.
(c) Form of records
Producing and/or keeping continuing-airworthiness records in a form acceptable to the
competent authority normally means in either physical or electronic copy, or a combination of
both.
Retention of records should be done in one of the following formats:
(1) original paper document or electronic data (via an approved electronically signed form);
(2) a paper reproduction of a paper document (original or copy); or
3. Draft AMC/GM
(3) an electronic reproduction of electronic data (original or copy); or

(4) a printed reproduction of electronic data (original or copy); or
(5) an electronically digitised reproduction of a paper document (original or copy); or
(6) a microfilm or scanned reproduction of a paper document (original or copy).
Where IT systems are used to retain documents and data, it should be possible to print a paper
version of the documents and data kept.
(d) Physical (non-digitised) records
All physical records should remain legible throughout the required retention period. Physical
records on either paper or microfilm systems should use robust material that withstands normal
handling, filing and ageing. They should be stored in a safe way to prevent damage, alteration
and theft.
(e) Digitised records
Digitised records may be created from a paper document (original or copy) or from electronic
data.
When created from a paper document:
(1) the creation date of the digitised record should be stored with the digitised record;
(2) it is advisable to create an individual digitised record for each document;
(3) if an organisation creates a large number of digitised records, the use of database
technology should ease the future retrieval of the record(s); and
(4) digitised records should be legible, including but not limited to details, such as the date of
signature, names, stamps, notes, or drawings.
(f) Digitised record retention
Digitised records when created from an original paper record, or as a digital electronic original,
should be stored on a system that is secured and kept in an environment protected from
damage (e.g. fire, flooding, excessive temperature or accidental erasing). IT systems should have
at least one backup system, which should be updated at least within 24 hours of any entry in the
primary system. Access to both primary and backup systems is required to be protected against
the ability of unauthorised personnel to alter the database and they should preferably be
located remotely from the main system.
The system used for retention of digitised records should:
(1) ensure the integrity, accuracy and completeness of the record;
(2) ensure that access to the digitised record has safeguards against alteration of the data;
(3) ensure the authenticity of the record including assurance that the date has not been
modified after creation;
(4) be capable of retrieval of individual records within a reasonable time period; and
3. Draft AMC/GM
(5) be maintained against technological obsolescence which would prevent printing,

displaying or retrieval of the digitised records.
Computer backup discs, tapes etc. should be stored in a different location from that containing
the current working discs, tapes, etc., and in a safe environment.
Where the competent authority has accepted a system for digitised record-keeping satisfying
the above, the paper documents may be permanently disposed of.
(g) Lost or destroyed records
Reconstruction of lost or destroyed records can be done by reference to other records which
reflect the time in service, by research of records maintained by maintenance organisations and
by reference to records maintained by individual mechanics, etc. When reconstruction has been
done and the record is still incomplete, the owner/operator may make a statement in the new
record describing the loss and establishing the time in service based on the research and the
best estimate of time in service. The reconstructed records should be submitted to the
competent authority for acceptance. The competent authority may require the performance of
additional maintenance if not satisfied with the reconstructed records.
14. New GM M.A.305(e) is added as follows:
GM M.A.305(e) Aircraft continuing-airworthiness record system

‘Until such time as the information contained therein is superseded by new information equivalent in
scope and detail but not less than 36 months’ means that during a maximum of 36 months, the
information and the one superseding it should be kept but, after these 36 months, only the new
information should be kept.
For example, for a maintenance task with an interval shorter than 36 months, more than one set of
information equivalent in scope and detail should be retained. If the maintenance task interval is
longer than 36 months, the last set of information equivalent in scope and detail is retained.
15. New AMC M.A.305(e)(1) is added as follows:

This retention period of 36 months may be extended in the case of an entry in the technical log system
requiring an additional period of retention as defined in Part-M.

(a) EASA Form 1 and the certificate of conformity of the components used to perform a
modification/repair are not part of the substantiation data for a modification/repair. These
documents are retained by the maintenance organisation.
(b) In the case of an AD with several steps or with intermediate assessments during its application,
these intermediate steps are part of the detailed maintenance records.
3. Draft AMC/GM

(a) EASA Form 1 and detailed maintenance records are not required to be kept to support every
installation/removal shown in the in-service history records.
(b) Conservative methods to manage missing historical periods are acceptable to establish the
current status of the LLP. In case of use of a conservative method, the supporting documents
should be endorsed. Recommendations from the design approval holder (DAH) on the
procedures to record or reconstruct the in-service history should be considered.
18. New GM M.A.305(e)(3) is added as follows:
GM M.A.305(e)(3) Aircraft continuing-airworthiness record system

(a) EASA Form 1 or equivalent is not required to be kept for ‘Condition monitoring’ process
components unless this is the means to fulfil another requirement of M.A.305 (e.g.
demonstration of AD compliance).
(b) For components that are not subject to any of the primary maintenance processes described
under GM M.A.305(d)(2) (i.e. ‘Hard time’, ‘On-condition’, ‘Condition monitoring’), EASA Form 1
or equivalent is not required to be kept.
19. New AMC M.A.305(f) is added as follows:
AMC M.A.305(f) Aircraft continuing-airworthiness record system

When the owner or CAMO arranges for the relevant maintenance organisation to retain copies of the
continuing-airworthiness records on their behalf, the owner or CAMO will continue to be responsible
for the retention of records. If they cease to be the owner or CAMO, they also remain responsible for
transferring the records to the new owner or CAMO.
20. AMC M.A.305(h) is deleted:
AMC M.A.305(h) Aircraft continuing airworthiness record system

When an owner/CAMO arranges for the relevant maintenance organisation to retain copies of the
continuing airworthiness records on their behalf, the owner/CAMO will continue to be responsible for
the retention of records. If they cease to be the owner/CAMO of the aircraft, they also remain
responsible for transferring the records to any other person who becomes the owner/CAMO of the
aircraft.
Keeping continuing airworthiness records in a form acceptable to the competent authority normally
means in paper form or on a computer database or a combination of both methods. Records stored in
microfilm or optical disc form are also acceptable. All records should remain legible throughout the
required retention period.
Paper systems should use robust material, which can withstand normal handling and filing.
3. Draft AMC/GM
Computer systems should have at least one backup system, which should be updated at least within 24
hours of any maintenance. Each terminal is required to contain programme safeguards against the
ability of unauthorised personnel to alter the database.
Continuing airworthiness records should be stored in a safe way with regard to damage, alteration and
theft. Computer backup discs, tapes etc., should be stored in a different location from that containing
the current working discs, tapes, etc., and in a safe environment. Reconstruction of lost or destroyed
records can be done by reference to other records which reflect the time in service, research of
records maintained by repair facilities and reference to records maintained by individual mechanics,
etc. When these things have been done and the record is still incomplete, the owner/CAMO may make
a statement in the new record describing the loss and establishing the time in service based on the
research and the best estimate of time in service. The reconstructed records should be submitted to
the competent authority for acceptance. The competent authority may require the performance of
additional maintenance if not satisfied with the reconstructed records.
21. AMC M.A.305(h)(6) is deleted:
AMC M.A.305(h)6 Aircraft continuing airworthiness record system

For the purpose of this paragraph, a ‘component vital to flight safety’ means a component that
includes certified life limited parts or is subject to airworthiness limitations or a major component such
as, undercarriage or flight controls.
22. AMC M.A.501(b) is amended as follows:
AMC M.A.501(b) Installation

(…)
3. The person referred to under M.A.801 or the M.A. Subpart F or Part 145 approved maintenance
organisation should be satisfied that the component in question meets the approved data/
standard, such as the required design and modification standards. This may be accomplished by
reference to the (S)TC holder or manufacturer’s parts catalogue or other approved data (i.e.
Service Bulletin). Care should also be taken in ensuring compliance with applicable AD and the
status of any service life-limited partsLLPs and TCCs fitted to the aircraft component.
23. New GM M.A.503 is added as follows:
GM M.A.503 LLPs and TCCs

The approved limitation is usually expressed in calendar time, flight hours, landings or cycles, as
appropriate.
24. AMC M.A.504(c) is amended as follows:
AMC M.A.504(c) Control of unserviceable components –— unsalvageable components

1. The following types of components should typically be classified as unsalvageable:
3. Draft AMC/GM
(…)
(d) certified life-limited partsLLPs that have reached or exceeded their certified life
limitsmandatory life limitation, or have missing or incomplete records;
(…)
(…)
25. AMC M.A.504(d)2 is amended as follows:
AMC M.A.504(d)(2) Control of unserviceable components

(…)
4. Since manufacturers producing approved aircraft components should maintain records of serial
numbers for ‘retired’ LLPscertified life-limited or other critical components, the organisation that
mutilates a component should provide the original manufacturer with the data plate and/or
serial number and final disposition of the component.
26. AMC M.A.613(a) is amended as follows:
AMC M.A.613(a) Component certificate of release to service

(…)
(…)
2.4. An EASA Form 1 issued in accordance with this paragraph 2 should be issued by signing in
block 14b and stating ‘Inspected/Tested’ in block 11. In addition, block 12 should specify:
(…)
2.4.4. detail of life used for service life-limited partsLLPs and TCCs being any combination
of fatigue, overhaul or storage life;
(…)
2.6. Used aircraft components removed from a serviceable aircraft.
2.6.1. Serviceable aircraft components removed from a Member State registered aircraft
may be issued an EASA Form 1 by an appropriately rated organisation subject to
compliance with this subparagraph.
(g) The flight hours/cycles/landings as applicable of any service life-limited
partsLLPs and TCCs including time since overhaul should be established.
(…)
2.8. Used aircraft components maintained by organisations not approved in accordance with
M.A Subpart F or Part 145.
(…)
3. Draft AMC/GM
(b) replacing of all service life-limited componentsLLPs and TCCs when no satisfactory
evidence of life used is available and/or the components are in an unsatisfactory
condition,
(…)
(…)
(…)
27. AMC M.A.710(a) is amended as follows:
AMC M.A.710(a) Airworthiness review

1. A full documented review is a check of at least the following categories of documents:
(…)
— Status list of service life-limited componentLLPs and TCCs
(…)
(…)
28. AMC M.A.901(d) and (g) is amended as follows:
AMC M.A.901(d) and (g) Aircraft airworthiness review

(…)
(g) Statement
(…)
The statement should confirm that the aircraft in its current configuration complies with the following:
(…)
— component service life limitationslimitation for LLPs and TCCs;
(…)
29. AMC M.A.904(a)(2) is amended as follows:
AMC M.A.904 (a)(2) Airworthiness reviews of aircraft imported into the EU

(…)
2. In determining the work to be undertaken during the airworthiness review on the aircraft, the
following should be taken into consideration:
(…)
(d) the aircraft continuing -airworthiness status such as the aircraft and component AD status,
the SB status, the maintenance status, the status of LLPs and TCCsall service life limited
components, weight and centre of gravity schedule including equipment list;
3. Draft AMC/GM
(…)
(…)
30. AMC M.A.904(b) is amended as follows:
AMC M.A.904(b) Airworthiness review of aircraft imported into the EU

The recommendation sent to the competent authority should contain at least the items described
below.
(…)
(c) Documents accompanying the recommendation
(…)
— status of all service life-limited componentsLLPs and TCCs;
(…)
(…)
31. Appendix XI to AMC M.A.708(c) is amended as follows:
Appendix XI to AMC M.A.708(c) Contracted maintenance

(…)
2.11 Service life-limited componentsLLPs and TCCs
The control of service life-limited componentsLLPs and TCCs is the responsibility of the CAMO.
The contract should specify whether the CAMO should provide the status of service life-limited
partsLLPs and TCCs to the maintenance organisation, and the information that the approved
organisation will have to provide to the CAMO about the service life-limited componentsLLPs
and TCCs’ removal/installation so that the CAMO may update its records (see also paragraph
2.22 ‘Exchange of information’).
(…)
32. Appendix II to AMC M.A.711(a)(3) is amended as follows:
Appendix II to AMC M.A.711(a)(3) Subcontracting of continuing -airworthiness management tasks

(…)
2.11 Service life limitMandatory life limitation or scheduled maintenance controls and component
control/removal forecast
(…)
2.15 Continuing -airworthiness records
They may be maintained and kept by the subcontracted organisation on behalf of the CAMO,
which remains the owner of these documents. However, the CAMO should be provided with the
current status of AD compliance and service life-limited componentsLLPs and TCCs in accordance
with the agreed procedures. The CAMO should also be granted unrestricted and timely access to
3. Draft AMC/GM
the original records as and when needed. Online access to the appropriate information systems
is acceptable.
3. AMC/GM
33. Appendix III to GM M.B.303(b) is amended as follows:

Appendix III to GM M.B.303(b) KEY RISK ELEMENTS
A.2 Airworthiness limitations An airworthiness limitation is a boundary beyond which an aircraft or a component thereof must not be
operated, unless the instruction(s) associated with this airworthiness limitation is complied with.
Supporting information Typical inspection items
Airworthiness limitations are exclusively associated with instructions whose 1. Check that the Aircraft Maintenance Programme (AMP) reflects airworthiness limitations and associated
compliance is mandatory as part of the type design. They apply to some instructions (standard or alternative) issued by the relevant design approval holders and is approved by
scheduled or unscheduled instructions that have been developed to prevent the competent authority, if applicable.
and/or to detect the most severe failure. 2. Check that the aircraft and the components thereof comply with the approved AMP.
They mainly apply to maintenance (mandatory modification, replacement, 3. Check the current status of life-limited partsLLPs. The current status of LLPslife-limited parts is to be
inspections, checks, etc., but can also apply to instructions to control critical maintained throughout the operating life of the part.
design configurations (for example Critical Design Configuration Control Typical Airworthiness Limitation items:
Limitations (CDCCL) for the fuel tank safety). - Safe Life ALI (SL ALI)/Life-limited parts LLPs,
- Damage Tolerant ALI (DT ALI)/Structure, including ageing aircraft structure,
- Certification Maintenance Requirements (CMR),
- Ageing Systems Maintenance (ASM), including Airworthiness Limitations for Electrical Wiring
Interconnection System (EWIS),
- Fuel Tank Ignition Prevention (FTIP)/Flammability Reduction Means (FRM),
- CDCCL, check wiring if any maintenance carried out in same area - wiring separation,
- Ageing fleet inspections mandated through ALS or AD are included in the AMP.
Reference documents: EASA - 21.A.31
- 21.A.61
- CS 22.1529
- CS 23.1529, Appendix G, para. G25.4
- CS 25.1529, Appendix H, para. H25.4
- CS 27.1529, Appendix A, para. A27.4
- CS 29.1529, Appendix A, para. A29.4
- CS 31HB.82
- CS-APU 30
- CS-E 25
- CS-P 40
- CS VLR.1529, Appendix A, para. A.VLR.4
- M.A.302
- M.A.305
- M.A.710(a)(7)
3. AMC/GM
A.3 Airworthiness Directives An Airworthiness Directive means a document 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 (Part 21A.3B).
Any Airworthiness Directive issued by a State of Design for an aircraft imported 1. Check if all ADs applicable to the airframe, engine(s), propeller(s) and equipment have been
from a third country, or for an engine, propeller, part or appliance imported incorporated in the AD-status, including their revisions.
from a third country and installed on an aircraft registered in a Member State, 2. Check records for correct AD applicability (including ADs incorrectly listed as non-applicable).
shall apply unless the Agency has issued a different Decision before the date of 3. Check by sampling in the current AD status that applicable ADs have been or are planned to be (as
entry into force of that airworthiness directive. appropriate) carried out within the requirements of these Airworthiness Directives, unless otherwise
specified by the Agency (AMOC).
4. Check that applicable ADs related to maintenance are included into the Aircraft Maintenance
Programme.
5. Check that task-cards correctly reflect AD requirements or refer to procedures and standard practises
referenced in ADs.
6. Sample during a physical survey some ADs for which compliance can be physically checked.
Reference documents: EASA - 21.A.3B
- 21.B.60
- 21.B.326
- 21.B.327
- M.A.303
- M.A.305(d) & (h)
- M.A.401(a) & (b)
- M.A.501(b)
- M.A.503(a)
- M.A.504(a) 2
- M.A.504 & AMC M.A.504(c) § 1 (f)
- M.A.613 & AMC M.A.613(a) § 2.4.3, 2.5.2, 2.6.1(h) & 2.8(b)
- M.A.708(b)8
- M.A.709(a)
- M.A.710(a)5
- M.A.801 & AMC M.A.801(h)
(…)
3. AMC/GM
B.2 Flight Manual A manual, associated with the certificate of airworthiness, containing operational limitations, instructions
and information necessary for the flight crew members for the safe operation of the aircraft.
The Flight Manual needs to reflect the current status/configuration of the 1. Check the conformity of the Flight Manual (FM), latest issue, with aircraft configuration, including
aircraft. When it does not, it may provide flight crew members with wrong modification status, (AD, SB, STC etc.).
information. 2. Check:
This may lead to errors and/or to override limitations that could contribute to - the FM approval, revision control, Supplement to FM;
severe failure. - the impact of modification status on noise and weight & balance;
- additional required manuals (QRH/FCOM/OM-B etc.);
- FM limitations.
Reference documents: EASA - 21.A.174(b)2(iii), (b)3(ii)
- 21.A.204(b)1(ii), (b)2(i)
- M.A.305, AMC M.A.305(d)
- M.A.710(a)2
- M.A.710(c)2
- AMC M.A.710(a)1
- AMC M.A.901(d) and (g)
- M.A.902(b)3
- AMC M.A.904(a)(2) points 2(c) and 2(k)
- AMC M.A.904(b) point (c)
B.3 Mass & balance Mass and balance data is required to make sure the aircraft is capable of operating within the approved envelope.
The mass and balance report needs to reflect the actual configuration of the 1. Check that mass and balance report is valid, considering current configuration.
aircraft. When it does not, the aircraft might be operated outside the certified 2. Make sure that modifications and repairs are taken into account in the report.
operating envelope. 3. Check that equipment status is recorded on the mass and balance report.
4. Compare current mass and balance report with previous report for consistency.
Reference documents: EASA - M.A.305(d)5
- M.A.708(b)(10)
- M.A.710(a)(9), AMC M.A.710(a)1
- Part-CAT: CAT.POL.MAB.100 and related AMCs/GM
- Part-NCC: NCC.POL.105 and related AMC/GM
- Part-NCO: NCO.POL.105 and related AMC/GM
- Part-SPO: SPO.POL.105 and related AMC/GM
(…)C.2 Component control The component control should consider a twofold objective for components maintenance:
3. AMC/GM
- maintenance for which compliance is mandatory.
- maintenance for which compliance is recommended.
Depending on each maintenance task, accomplishment is scheduled or 1. Check that the mandatory maintenance tasks are identified as such and managed separately from
unscheduled. Refer to KRE C.1 ‘Aircraft Maintenance Programme’. recommendations.
Components affected by scheduled maintenance: 2. Sample check installed components (PN and SN) against aircraft records:
Life-limited components are of two types: a. Correct Part Number and Serial Number installed.
- components subject to a certified life limit; b. Correct authorised release document available.
- components subject to a service life limit. 3. Check the current status of time-controlled components, with due consideration to deferred items.
Components with a certified life-limitmandatory life limitation and LLPs, must They must identify:
be permanently removed from service when, or before, their operating a. The affected components (Part Number and Serial Number).
limitation is exceeded. The life limitation is controlled at the component level b. For components subject to a repetitive task: the task description and reference, the applicable
(in opposition to aircraft level). threshold/interval, the last accomplishment data (date, the component’s total accumulated life in
Components which are TCCssubject to a service life (‘time-controlled Hours, Cycles, Landings, Calendar time, as necessary) and the next planned accomplishment data.
components’) include the following: c. For components subject to an unscheduled task: the task description and reference, the
- components for which removal and restoration are scheduled, regardless of accomplishment data (date, the component’s total accumulated life in Hours, Cycles, Landings,
their level of failure resistance. Reference is made to hard time Calendar time, as necessary). Pay attention to ETOPS and CDCCL components.
components: They are subject to periodic maintenance dealing with a 4. Check current status of LLPslife-limited components. This status can be requested upon each
deterioration that is assumed to be predictable (the overall reliability transfer throughout the operating life of the part:
invariably decreases with age): Failure is less likely to occur before a. The life limitation, the component’s total accumulated life, and the life remaining before the
restoration is necessary; component’s life limitation is reached (indicating Hours, Cycles, Landings, Calendar time, as
- components for which failure resistance can reduce and drop below a necessary).
defined level: Inspections are scheduled to detect potential failures. b. If relevant for the determination of the remaining life, a full installation history indicating the
Reference is made to ‘On-condition’ components: They are called such number of hours, cycles or calendar time relevant to each installation on these different types of
because components, which are inspected, are left in service (no further aircraft/engine.
maintenance action taken) on the condition that they continue to meet 5. Check if the aircraft maintenance programme and reliability programme results impact the
specified performance standards. component control.
Notes: 6. Check that LLPs and TCCs life-limited and time controlled components are correctly marked during
1. Restoration tasks for hard time components are not the same as ‘On- a physical survey.
condition’ tasks, since they do not monitor gradual deterioration, but are
primarily done to ensure the item may continue to remain in service until
the next planned restoration.
2. Components subject to ‘condition-monitoring’ are permitted to remain in
service without preventive maintenance until functional failure occurs.
Reference is made to ‘fly-to-failure’. Such components are subject to
unscheduled tasks.
3. AMC/GM
Reference documents: EASA - 21.A.805
- M.A.302
- M.A.305
- M.A.501
- M.A.503
- M.A.710
(…)
C.4 Records Continuing -airworthiness records are defined in M.A.305 and M.A.306 and related AMCs.
Retention/Transfer of the records is required so that the status of the aircraft 1. Check the aircraft continuing -airworthiness record system: M.A.305 and M.A.306, as applicable,
and its components can be readily established at any time. require that certain records are kept for defined periods.
Task accomplishment is scheduled (one time or periodically), or unscheduled Pay attention to the continuity, integrity and traceability of records:
(e.g. following an event). Aircraft continuing -airworthiness records (refer to a. integrity: Check the data recorded is legible,
logbooks, technical logbooks, component log cards or task cards) shall provide b. continuity: Check that records are available for the applicable retention period,
the status with regard to: c. traceability: Check the link between operator/CAMO and maintenance documentation, traceability
- scheduled tasks: to approved data, traceability to appropriate release documents, etc.
- one-time: life-limited partsLLPs status, modification status, repair status. 2. If applicable, make sure that the tech log system is used correctly, including:
- repetitive: maintenance programme status. a. current aircraft release to service (including the maintenance statement) issued and
- unscheduled tasks. b. pre-flight inspections signed-off by authorised persons;
3. Check that any maintenance required following abnormal operation/event (such as overspeed,
overweight operation, hard landing, excessive turbulence, and operation outside of Flight Manual
limitations) has been performed, as applicable.
Reference documents: EASA - M.A.305
- M.A.306
- M.A.307
- M.A.801
- AMCs M.A.305
- AMCs M.A.306
- AMC M.A.307
(…)
3. Draft AMC/GM
3.2. Draft AMC/GM to Part-145
1. AMC No 2 to 145.A.50(d) is amended as follows:
AMC No 2 to 145.A.50(d) Certification of maintenance

(…)
2. In the case of the issue of EASA Form 1 for components in storage before Part 145 and Part 21
became effective and not released on an EASA Form 1 or equivalent in accordance with
145.A.42(a) or removed serviceable from a serviceable aircraft or an aircraft which has been
withdrawn from service the following applies:
(…)
(…)
2.4.4. Detail of life used for service life-limited partslife limited parts (LLPs) and time
controlled components (TCCs) being any combination of fatigue, overhaul or
storage life.
(…)
2.6.1 Serviceable aircraft components removed from a Member State registered aircraft
may be issued with an EASA Form 1 by an appropriately rated organisation subject
to compliance with this subparagraph.
(…)
(g) The flight hours/cycles/landings as applicable of any service life-limited
partsLLPs and TCCs including time since overhaul should be established.
(…)
(…)
(…)
2.8. Used aircraft components maintained by organisations not approved in accordance with
Part 145. For used components maintained by a maintenance organisation not approved
under Part 145, due care should be taken before acceptance of such components. In such
cases an appropriately rated maintenance organisation approved under Part 145 should
establish satisfactory conditions by:
(…)
(b) replacing all service life-limit componentsLLPs and TCCs when no satisfactory
evidence of life used is available and/or the components are in an unsatisfactory
condition;
(…)
(…)
3. Draft AMC/GM
2. GM 145.A.55 (a) is amended as follows:
GM 145.A.55(a) Maintenance and airworthiness review records

1. Properly executed and retained records provide owners, operators and maintenance personnel
with information essential in controlling unscheduled and scheduled maintenance, and trouble
shooting to eliminate the need for re-inspection and rework to establish airworthiness.
The prime objective is to have secure and easily retrievable records with comprehensive and
legible contents. The aircraft record should contain basic details of all serialised aircraft
components and all other significant aircraft components installed during the maintenance
performed, to ensure traceability to such installed aircraft component documentation and
associated maintenance data as specified in 145.A.45.
(…)
3.3. Draft AMC/GM to Part-CAT
1. New AMC1 CAT.IDE.A.105 is added as follows:
AMC1 CAT.IDE.A.105 Minimum equipment for flight

GENERAL
The operator should control and retain the status of instruments, equipment or functions required for
the intended operation, that are not controlled for the purpose of continuing-airworthiness
management. Examples of such instruments, equipment or functions may be but are not limited to
equipment related to navigation approvals as FM immunity or certain software versions.
2. New GM1 CAT.IDE.A.105 is added as follows:
GM1 CAT.IDE.A.105 Minimum equipment for flight

GENERAL
The operator should define responsibilities and procedures to control and retain the status of
instruments, equipment or functions required for the intended operation, that are not controlled for
the purpose of continuing-airworthiness management.
3. New AMC1 CAT.IDE.H.105 is added as follows:
AMC1 CAT.IDE.H.105 Minimum equipment for flight

GENERAL
3. Draft AMC/GM
4. New GM1 CAT.IDE.H.105 is added as follows:
GM1 CAT.IDE.H.105 Minimum equipment for flight

GENERAL
3.4. Draft AMC/GM to Part-NCC
1. New AMC1 NCC.IDE.A.105 is added as follows:
AMC1 NCC.IDE.A.105 Minimum equipment for flight

GENERAL
2. New GM1 NCC.IDE.A.105 is added as follows:
GM1 NCC.IDE.A.105 Minimum equipment for flight

GENERAL
3. New AMC1 NCC.IDE.H.105 is added as follows:
AMC1 NCC.IDE.H.105 Minimum equipment for flight

GENERAL
4. New GM1 NCC.IDE.H.105 is added as follows:
GM1 NCC.IDE.H.105 Minimum equipment for flight

GENERAL
instruments, equipment or functions, required for the intended operation, that are not controlled for
3. Draft AMC/GM
3.5. Draft AMC/GM to Part-NCO
1. New AMC1 NCO.IDE.A.105 is added as follows:
AMC1 NCO.IDE.A.105 Minimum equipment for flight

GENERAL
2. New AMC1 NCO.IDE.H.105 is added as follows:
AMC1 NCO.IDE.H.105 Minimum equipment for flight

GENERAL
3.6. Draft AMC/GM to Part-SPO
1. New AMC1 SPO.IDE.A.105 is added as follows:
AMC1 SPO.IDE.A.105 Minimum equipment for flight

GENERAL
2. New AMC1 SPO.IDE.H.105 is added as follows:
AMC1 SPO.IDE.H.105 Minimum equipment for flight

GENERAL
4. Individual comments
(General comments) -
comment 4 comment by: ACE

Thanks for the proposed clarification. We think these changes wil be very useful.
comment 27 comment by: Liam CREAVEN

The NPA content is strongly supported by my organisation since it provides useful and
significant clarification concerning the data that must be retained by the Operator. The
present version of the affected sections of Part M is leading to unnecessary costs and
confusion in our industry. Positive benefits may be expected when the NPA changes are
adopted including easing the transfer of aircraft within Europe. My organisation is however
concerned that the timetable for publication date of the Opinion (Q1 of 2017) is not
expeditious enough and we therefore urge the Agency to accelerate the process.
response
comment 28 comment by: Federal Office of Civil Aviation FOCA

FOCA fully supports the NPA 2014-04. It contains the necessary clarification on electronic
storage for continuing airworthiness records systems.
We positively note that finally the retention periods of technical documents have been
streamlined across all the relevant regulations.
response
comment 35 comment by: René Meier, Europe Air Sports

Europe Air Sports (EAS), European Powered Flying Union (EPFU) and the Aero-Club of
Switzerland joined forces to comment on NPA 2014-04 Technical Records, thanking the
Agency for the preparation of the document.
Theses comments are supported by the Provisional Executive Committee of European
Ballooning Federation.
The four organisations fully support the positions of European Gliding Union and of the
European Sailplane Manufacturers.
In addition I would like to add the fact that until recently I was president of the Segel- und
Motorfluggruppe Grenchen/Flugschule Grenchen, operating 16 powered aircraft and 12
sailplanes. I guided this organisation during the transformation process form FTO to ATO, I
have several hundred flight hours on my log book and made several hundred glider-towing
flights as well. For all this I feel competent to make the statements that follow, which go in
the direction that the realities of General Aviation operations were not sufficiently
considered by the persons who prepared this NPA, otherwise we would find proposoals for
provisions for RF/FTO/ATO (whichever is in place), and for our club operations, where one
pilot easily performs more than a dozen of flight per day, in parachute-jumping and
sailplane-towing operations, in helicopter operations, without stopping the engine between
flights. In winch-towing operations with sailplanes during basic training which result in short
flight, easily even more than four dozens of flights are performed in a day. How does the
Agency think logbook entries should be made after each flight?
In our view the RIA you propose shows us that the authors of this NPA are not familiar with
our operations. We are sorry to be obliged to write that again a "one size fits all" solution is
proposed, despite dozens of pages were publihed in the past making us believe that GA's
situation is known to them, particularly after creating the "Part-M for General Aviation Task
Force".
In one sentence: We accept all proposals increasing the safety of flight at affordable cost, we
reject all ideas only creating costs without any real safety benefit and which do not respect
the statements proposed the many "Part-M for General Aviation Task Force" texts, as well as
the statements in the "European General Aviation Safety Strategy", a discussion paper dated
38 August 2012, and the "Roadmap for Regulation of General Aviation", a working paper
dated 18 November 2012.
response
comment 47 comment by: EUROCONTROL

The EUROCONTROL Agency does not have any comment on NPA 2014 - 04.
response
comment 63 comment by: AIRBUS

Airbus holds organisation approval certificates in addition to the certificates issued under
Part-21:
- Airbus holds a certificate for a Continuing Airworthiness Management Organization
(CAMO).
- Airbus also holds several Part-145 (or equivalent) certificates granted by National
Airworthiness Authorities according to their specific regulations for maintenance
organisations.
On the basis of its knowledge and experience gained in these fields, Airbus would like to
commend the work undertaken by the Agency and the rulemaking working group. The
outcome achieved is valuable. For example, the definitions given in the GM M.A.305 will
contribute to eliminate some grey areas in the way to appropriately manage maintenance
and aircraft continuing airworthiness records, in particular for components, including
software. The result of this work will also participate in concentrating Part-M community
efforts on records essential to the aircraft continuing airworthiness and in ensuring
consistency with Part-145, while minimizing the records archiving costs.
Airbus submits additional comments aiming at complementing this important achievement.
response

Airbus does consider the options available and their implications before giving preference to
an implementation strategy. The objective is to achieve a pragmatic and practicable
application of proposed regulation amendments. In some cases, the overall benefits support
the case for early adoption, whilst in others a later timetable is more suitable.
In the present case, the reorganisation of the point M.A.305, in particular for the new
paragraphs (d) and (e), and the clarifications introduced in the different AMC and GM of the
point M.A.305 will contribute to:
– Streamline the aircraft continuing airworthiness record system (with better consideration
given to components and new Information Technology tools) and its connection with
maintenance records,
– Give coherence and direction to produce, keep and retain aircraft continuing airworthiness
records for components,
– Enhance cost-efficiency in the aircraft continuing airworthiness record process.
Therefore, Airbus is in favour of an early adoption in order to maximize safety benefits and
savings on archiving costs the proposed amendments will produce. 2015Q3 is proposed for
the publication date of the Opinion.
response
comment 172 comment by: Swiss International Airlines / Bruno Pfister

ð
General Comments
SWISS supports the NPA although it is considered to be costly (time consuming and involving
extra manpower).
A timely information campaign/training aid for involved Part-M staff should be provided.
Specific Comment
Ref 4.3.3 SWSS considers the interpretation of “back to birth” as being critical and therefore
favours Option 2
response
comment 181 comment by: Chris GRUENER, BOC Aviation Pte. Ltd.
The terms owner/operator are intermingled, a clear separation should be stated as to their
responsibility regarding commercial aviation. If the term "owner" is only required to cover
general aviation, a more precise terminology would be good in order to avoid confusion with
aircraft lessors/financers (e.g. person responsible for airworthiness compliance). This applies
to a number of paragraphs in the regulation.
response
The new regulation marks a clear improvement over the current regulation. It clarifies and
removes uncertainties. Therefore it should be aimed to introduce this regulation earlier than
Q1/2017.
response
comment 183 comment by: Howard Torode

Comment by European Gliding Union - General Comment
While this NPA clearly applies to GA, it was developed without consultation with the Task
Force on Part M for General Aviation (GATF). It has clearly been written by Commercial Air
Transport people on the 'one size fits all' principle, without any consideration of GA
operational circumstances. This is poor procedural practice by EASA, and demonstrates a
continuing failure to appreciate the needs of GA. This is contrary to EASA's own policy and
position as recently expressed, for example, in EASA presentations at Friedrichshafen.
Further, it is poorly written with non-standard phraseology and colloquialisms that most
European's will not understand, and needs full editing for consistency and clarity. EGU as a
minimum supports Europe Air Sports editorial comments.
response
comment 209 comment by: Luftfahrt-Bundesamt

The LBA has no comments on NPA 2014-04.
response
comment 263 comment by: DGAC France

DGAC France supports the aim of this NPA to clarify :
- what should be kept and for how long in technical records;

- the use of new technologies for record-keeping.
response

The NPA is quite clear about the records necessary to determine the status of airworthiness
of an aircraft, including its engines, components.
But DGAC France wonders how additional records, mainly from an operational source,
should be addressed:
- hard-landing reports and following inspections, possibly impacting LDG and life limited
parts
-Reliability reports for ETOPS operations
- Engine trend monitoring information
response

The NPA clarifies within MA.305 and associated AMC/GM what the aircraft continuing
airworthiness records system is, with the aim to determine the airworthiness of an aircraft.
There is no similar description of what documentation shall be associated with components
on the shelf. For instance, when an engine is removed from an aircraft and another s/n one is
mounted, the overall aircraft records per M.A.305 will trace the new s/n engine. But the
removed s/n engine should have its own records and it is possibly worth describing that in an
AMC to M.A.501 (b).
response

As the AMC MA305(h) has been reviewed with regard to IT systems and digitized record,
DGAC recommends to review AMC MA714 accordingly.
The following parallels can be drawn:
- AMC MA714(3) AMC MA305(e)(c)
- AMC MA714(4) AMC MA305(e)(d)
- AMC MA714(5) AMC MA305(e)(e)
- AMC MA714(6) AMC MA305(e)(f)
response
comment 287 comment by: European Sailplane Manufacturers

The European sailplane manufacturers have some general comments to NPA 2014-04 about
"Technical records".
From the perspective of the lower end of European aviation we must emphasize again, that
the "one size fits all" approach at EASA rulemaking becomes visible again.
When looking through the list of issues to be addressed in chapter 2.1 we find mostly issues
which are not relevant to small aircraft and/or will only make things more complicated for
our communities.
It is understood that Part-M has to be applicable to sailplanes as well as airliners, but if Part-
M is changed in a way, that the change itself alone creates a lot of additional effort without a
real benefit, then it is not acceptable.
Our main issue lies with the proposal to replace the "life limited parts" and "service life
limited parts" with other terms.
Even if these old terms are in some cases not as precise as it could be desired, a replacement
of terms will have large consequences.
Aircraft maintenance programmes, maintenance manuals of products, manuals of approved
organisations, official publications by authorities and other organisations - all will be affected
if these long used terms will be re-defined or replaced.
For us this is an example, where the will to do rulemaking seems to be much higher than the
will to get to more workable regulations.
It is also an example how the RIA is really not used to make an assessment but to simply
express that the proposed changes shall be done.
Alone the first paragraph of the "Safety risks" chapter in the RIA is not more or less than a
general excuse for the perception that even more paperwork is considered to be increasing
safety. It is really even more unveiling that here the main reason given is the stated
propability for an accident of a large aircraft.
Proceeding further in the RIA shows that in most cases the assessing team saw no problems
for General Aviation (under point 5) within the RIAs for each sub-tasks. This only shows that
no real consideration was done in that respect.
Looking further into the RIA it is also quite obscure how sometimes 1 / 2 / 3 points are given
- for an outsider this rather seems to be difficult to understand or to accept.
This results into a fine table where numbers can be added and compared, but in the end we
do not find a real assessment about the possible effort, which has to be spent on the side of
stakeholders to implement the proposed changes.
It is easy to decide that safety goes up three points (whatever this is) and to claim that GA
and/or economics are not or only slightly affected.
The end result is always an inclination toward a proposed change as the rulemaker is then
finished and others have the problem to implement and make it work.
Going back to the issues to be addressed, the sailplane manucaturers have no problem to
make it easier to clarify record-keeping periods, allow more electronic means in
documenting and marking of parts and making it easier for organisations dealing with EASA
and FAA.
But we really oppose change in th erules which will create a lot of effort, increase the
implementation efforts by the NAAs and create costs without a safety benefit.
response

The European sailplane manufacturers want to point out that this NPA has not been analysed
until now in the General Aviation Part-M Task Force.
This task force has been established by EASA in February 2012 after a workshop in autumn
2011 where the General Aviation communities expressed their great frustration about the
fact that Part-M is not very helpful in their communities due to the complicated structure
and the need to fit to all sizes of aircraft.
It was explained by EASA to GA stakeholders and the tsk force members, that from now on
the task force shall look into all GA-related rulemaking for Part-M in order to avoid further
detoriating of the already difficult situation.
In the case of NPA 2014-04 this promise has not been kept.
The sailplane manufacturers have a seat in the task force and herewith demand that EASA
stays to such promises.
As commented in the other inputs, this NPA will create a considerable effort also in the GA
communities and it is nothing less than an affront if EASA makes such promises and then
üublished such NPA.
This is even more disturbing when it is considered that also the group composition of the
underlying MDM.076 task shows no indication that the needs of GA have been taken into
account.
This total ignorance of the needs of GA and the lack of willingness to improve is in total
contradiction to the new stated goals as outlined in the EASA GA roadmap, which was
announced with great fanfare in spring 2014.
No wonder many GA stakeholder are rather sceptical....
response

As already explained before, the European sailplane manufacturers see the most problems
with the re-definition and replacement of the terms ‘Life Limited Parts’ and ‘Service Life
Limited Parts’.
When looking into the ToR it was only stated that these terms today are inconsistent in the
use of it.
It was nowhere asked in the ToR to replace the terms.
As explained before we see a lot of possible consequences by such a replacement of terms
and therefore do oppose this proposal.
We propose as alternative to do what was asked for in the ToR: to issue the inconsistencies
of the use of these terms as is been done today.
(Why should the SSCC issue ToR if they are not followed?)
response
comment 337 comment by: Luftsport Verband Bayern / Germany

From the view of General Aviation and the glider community in Europe this is an NPA which
solves a problem which does not exist in this environment. This NPA may solve problems in
the commerial environment but not in the GA.
On the contrary implementing this NPA will create the need for more paperwork in our
environment without having a benefit, as detailed later in the chapter related comments,
even in the light that EASA states itself that an accident deriving from the old "unprecise"
terms is not known (chapter 4.1).
Stating "no impact" for General Aviation (chapter 4.4) shows that GA was not really involved
in preparing this NPA.
Redefining the terms as proposed here may solve some old questions but will create a lot of
new questions regarding the use of old aircraft or component manuals, organisation
manuals, publications by NAAs and so on.
response
comment 368 comment by: FAA

1. 1. The record retention periods are significantly longer than FAA requirements (several
locations).
2. 2. The conversion from U.S. records requirements to EASA standard may be difficult to
impossible due to detail and retention period differences.
3.
3. Proposed Point GM M.A.305(d)(2) - Definitions of “time controlled,” “hard time,” and “on-
condition” etc. should be furnished in the definitions in the front of the document.
response
comment 371 comment by: NFO Technical Commitee

The aviation industri need to develop better software program. When i use my B1/B2 to give
a CSR Certificate of Release to Service i spend a lot of time in front of the computer instead
of repair or troubleshoot on the aircraft. And some of the manufacturer made some very
time consuming Maintenance Manuals to.
I will give the Comment Response Tool used in EASA a big smile. Easy to understand and
make comments.
response
comment 373 comment by: Aviation Working Group

Attachment #1
Please see attached AWG's comments on NPA 2014-04
response
Applicability — Process map p. 1
comment 221 comment by: Eamon STAPLETON

Reference document FAA AC 120-16E was cancelled and replaced by FAA AC 120-16F in
November 2012.
response
EXECUTIVE SUMMARY p. 1

Page 1/44
Executive Summary
Based on safety recommendation UNKG 2007-91 the Agency initiated the Rulemaking Task
and its NPA we are discussing here.
Considering the extremely wide scope of aviation we do not think that this initiative will
bring good results as e.g. provisions for CAT operators are in no way identical to the needs of
a flying club.
We read in the second paragraph of the Executive Summary of "not clear enough
provisions". Unfortunately terms proposed in the NPA like "dirty finger prints" and
"conservative" are not clear enough as well and must be replaced to reduce possible
misinterpretations to a strict minimum. "Hard time" surely will be misunderstood, despite

the definition the Agency proposes
Rationale:
Future AMC/GM will not be translated offically, for this reason we need expressions not
leading to confusion as we address non-native readers of texts written in English.
What we really to not like is the wording "...has been destroyed...", neither here in the
Executive Summary nor in the following text.
Proposal:
Please write "....permanently removed from service" only. "Dismantled" would be another
acceptable term. And also do it in 4.1. and in 4.1.1.
Rationale:
Nobody wishes do destroy an aircraft deliberately: An aircraft is destroyed in an accident,
probably written off due to a ground fire, its situation may eventually be "beyond
economical repair", it might be permanently stored, scrapped or wrecked but simply
destroyed in the pure sense of the word is very unlikely a situation.
response
comment 195 comment by: Swedish Transport Agency

Swedish Transport Agency (STA) comments to NPA 2014-04 Technical records
The general impression is that we agree the proposed changes to clarify the intension of the
technical records for continuing airworthiness.
response
comment 336 comment by: SVFB/SAMA

ECOGAS
Representing Small and Medium Enterprises
This community is making a living for the Owners (Entrepreneurs), their families and their
employes and their families.
This community is most hit by overregulation.
We are aware of the changes in preparation for part of the recreational aviation, which we
support and appreciate the efforts.
For SME's we are expecting urgent and concrete results, should not more SME's close down
and jobs lost.
We quote from the "Executive summary:
"This evaluation is always done taking into account different operations/aircraft, so the less
complex aviation community is not imposed to hold records in the same way that more
complex ones are."
We propose that there is no change to all aviation up to 5.7, unless it's a change which
reduces administrative work in a proven and stakeholder accepted way.
Any safety recommendation from a AAIB should be seen in the context of a risk based
approach and should only lead to legal change after an economical impact assessment on
SME's in comparison to a forecasted improvement in safety.
“This NPA and the decision eventually coming out of it will be limited to Public Air Transport
by Scheduled Airlines and Maintenance Organisations involved Scheduled Air Transport and
Scheduled operations” we could accept it"
Without such limitation, we see the potential for more burden without safety benefit for
SME's.
We repeat here once more, the data for the substantiation of a new rule:
- must be shown in full
- must be true
- must be valid
- must be transparent (this is not the case for the table with the conclusions)
- must be important ( what risks will be mitigated >? <Yes its ok for scheduled commercial
airtransport)
- and it should generate a ROI for GA as well, in any case it should not be negative for any
sector of GA.
response
Table of contents p. 2-3
comment 293 comment by: Regio Lease

Generally in this NPA we use the term "applicable parameter" (which is defined on page 15)
and the terms of its definition such as : flight hours, landing, cycles.
It is a bit disturbing in the understanding and though not really in line with the definition.
response
2. Explanatory Note p. 5-9

Page 5/44
2.2. Objectives
Cost efficient rules? When it comes to M.A.305 (b) 1. we find that totally unnecessary costs
are produced when the proposed provisions will become applicable to most of the General
Aviations operators, as a matter of fact, cost efficient operations will be hindered by rules
having nothing in common with efficiency and with effectiveness.
Rationale:
The Agency's proposal is in no way cost efficient, it produces an additional administrative
burden on operators of aircraft of non-complex design, if we shall not get provisions adapted
to our needs.
response
comment 202 comment by: Klaus Lehmkoester - CAMO, DE.MG.1016, LBA.MG.1016

FAA: Yes, but make it easyer. Do a copy/paste of FAA rules and delete all the EASA rules!
And, in future, there no need of the EASA authority!!!
response

Life limited parts:
I think, with this action you will open a backdoor to legalise your failed directive with the life
limited parts and TBOs.
Please make a proposal what you will do with aircrafts older then about 20 years?
response

General remark:
Who did this NPA? When I read this, there is absolutly no compliance with the task force for
Part-M!!!
You said at the AERO in Friedrichshafen everything will come easyer. But with this NPA and
no feedback from the task force erything will come much more difficulter.
What is the aim and advantage of this excessive collection and documentation of data? Is
there anybody in the EASA or national authorities who evaluated these data; e. g. do a
reliability analysis with Weibull? Which sense is behind a “Life Limited Part” and “Service Life
Limited Part”? Safety? I do not think so. I think several manufactures only want to earn an
extra money with short limited parts. There is absolutly no control of failed parts and
suspended parts in the general aviation.
Examples:
- The (motor-)starter from “Sky-Tec” have a lifetime of 2,000 h (used in C172 or Pa28). This
means by a starting procedure of 15 seconds you can use this starter 4 times a minute or
480,000 times within his lifetime. Who will watch this?
- A modern glider has 6,000 h lifetime and with prolonging up to 12,000 h. By about 150
h/year you can fly it for 40/80 years. I think your personal lifetime is terminated before …
- Hoses from “Aeroquip” with same used oil have different lifetime, depends only to the
authorities not to the aircraft manufacturer …
L'Hotellier connectors: Lifetime 10 years! Wether one hour in use or thousands. What a
horror!
Lifetime limits may can have sense for big airplanes, but not for small one in the general
aviation. Please compare this with your own car: How you collect lifetime data? Are there
any one? Which kind of technical records you uses? How often you change the motor in your
car? Any average vehicle on our roads are much more complex than any Cessna or Piper or
any glider!
Micro light airplanes: Same Rotax motor as in certified airplanes, but no lifetime control.
How does this match? Same for other parts, like hoses and …
response
comment 261 comment by: Dassault Aviation

Dassault-aviation comment pages 6,35,40,43,21-22
“Lack of guidance on the acceptability of new technology, such as RFID (Radio Frequency
Identification) "
It seems regrettable to exclude evolutionary technologies -as RFID- of acceptable means.
Dassault-Aviation suggest to add a future opportunity for RFID use when this technology will
be on control.
response

We should ensure that the term "back to birth" is not used as is in the manufacturer
documentation. We have verified on the Airbus ALS documentation, howver we have a
doubt on some other OEMs such as CFMi.
response
Page 5/44
2.1. Overview
The inconsistency in the use of the terms "Life limited Parts" and "Service Life Limited Parts"
is not a real problem.
Rationale:
Different interpretations occur because different languages are spoken in Europe, because
AMC/GM are normally not translated, because from the start terms lacking precision like
"back to birth" or "dirty finger prints" are accepted in official texts.
We see a risk in the fact mentioned above when we write about missing translations of
AMC/GM: Most probably NAA's then only refer to "hard law" available in their language,
they reduce therefore existing freedom of action and available reasonable interpretation to a
minimum, probably to the detriment of General Aviation.
response

2.2 If the objectives of the EASA System would not take into account in addition to the
primary purpose
to protect it's public AND to promote the well being of the citizens of Europe, the excuse
could only come from
that of timing.
The regulation was made in a time of a positive economical outlook.
Even so, it takes somewhat into account that regulation must be cost efficient.
We estimate that the meaning of the following article is that the regulation
must be cost efficient not mainly for the regulator, but for the regulated.
If this should not be the case, then there is need to change the regulation.
Article 2 (c) of the BR 2016/2008 states:
"(c) to promote cost-efficiency in the regulatory and certification
processes and to avoid duplication at national and European level";
The application of this article demands that the economical effect eventually caused by the
application of the amended regulation must not be negative; in fact it requests the effect
to be positive.
The effect on GA (definition of the GA: all aviation except airlines and state aircraft)
must made transparent to the GA Stakeholder and must not be implemented if negative and
needs their full consent.

To make the process economically more efficient , we propose that legislation is changed in
the
BR 2016/2008 as it has been successfully done in other parts of the legislation as for example
in 1254/2009 which states in article 1:
Article 1
Member States may derogate from the common basic standards referred to in Article 4(1) of
Regulation (EC) No 300/2008 and
adopt alternative security measures that provide an adequate level of protection on the
basis of a local risk assessment at airports or demarcated areas of airports where traffic is
limited to one or more of the following categories:
1. aircraft with a maximum take-off weight of less than 15 000 kilograms;
2. helicopters;
3. law enforcement flights;
4. fire suppression flights;
5. flights for medical services, emergency or rescue services;
6. research and development flights;
7. flights for aerial work;
8. humanitarian aid flights;
9. flights operated by air carriers, aircraft manufacturers or maintenance companies,
transporting neither passengers and baggage, nor cargo and mail;
10. flights with aircraft with a maximum take-off weight of less than 45 500 kilograms for the
carriage of own staff and non fare-paying passengers or goods as an aid to the conduct of
company business.
Introduction of such boundaries as excluding aircraft up to 15'000 kg and /45'000 kg into
2016/2008 would probably solve many if not most or all of the problems faced by GA and
especially by SME's.
If such proceedings was possible in 1254/2009 for Aerodromes, why should it not be the
appropriate and Risk based approach for Part 145,Part M, Part 66, Part 147 ?
2.3 We appreciate the intent to make things better and simpler.
The question is: will they be simpler for all players below the airline environment ?
If this can be demonstrated before the rule becomes valid,only then we would support it.
The intro of the wording "Technical Log system" and the correlated required data processing
is good for the airline environment and for aircraft above 15'000 kg/45'000kg, but we
suspect creation of undue burden below such limits and a heavy burden for recreational
aviation in any case.

The present application of the Term "Commercial Airtransport" prevents application of
legislation in a proportionate and risk based manner, it would be adequate if changed to
"Scheduled commercial airtransport".
What risks does the Agency exactly want to address ?
The loss of an A330 or the loss of a limited number of lives ?
In the later case it's not demonstrated that a change will have the intended effect.
response
comment 351 comment by: Ralf Keil

Bereits in den einführenden Erläuterungen zur NPA 2014-04 zeigt die EASA eine Differenz
zwischen der Ankündigung und Umsetzung des Willens zur Schaffung deutlicher
Erleichterungen für die Allgemeine Luftfahrt, insbesondere dessen „Light End“. Speziell für
Luftfahrzeuge nach ELA 1 und ELA 2 werden nach dem Willen dieser NPA einmal mehr
Begrifflichkeiten und Regulierungen der kommerziellen Luftfahrt übernommen, die weder
praxisnah noch bisher üblich sind.
Die NPA versucht Begrifflichkeiten neu zu definieren und reißt dabei Lücken auf die neue
Fragen stellen, aber unbeantwortet bleiben. Damit schafft die EASA bei den Haltern
einfacher Luftfahrzeuge einmal mehr Verwirrung.
Insgesamt erinnert die NPA aus der Sicht des Luftsports an die NPA/Opinion zu den TBO im
Jahre 2013. Insgesamt war sicherlich auch diese Decision 2013/025/R in ihrem Ansatz gut
gemeint, war aber für die Allgemeine Luftfahrt zu kompliziert, wenig praxisnah und ließ den
nationalen Behörden so viel Gestaltungsspielraum, dass eine europaweit einheitliche
Umsetzung der Decision unmöglich wurde. Den betroffenen Luftfahrern wurde damit eher
geschadet als ihnen zu helfen.
Das Schicksal der Rücknahme durch die Decision 2013/034/R ist bekannt.
In der vorliegenden NPA zeigen sich ähnliche Ansätze, welche besonders für das „lighter
End“ der der Allgemeinen Luftfahrt unter dem Aspekt einer regiden Umsetzung durch die
nationalen Behörden unbillig harte Entscheidungen erwarten lassen.
Auch wenn ich bei den konkreten Punkten gesondert Stellung nehmen werde, hier schon
einmal die Zusammenfassung der nachfolgenden Kommentare:
1. Der Versuch der besseren Definition und Klarstellung der Begrifflichkeiten von
„laufzeitkontrollieren Komponenten“ und „lebenszeitbegrenzten Bauteilen“ und deren
Dokumentation löst nicht das Problem der Allgemeinen Luftfahrt, weil es von Herstellern
sowohl Empfehlungen als auch Forderungen nach Laufzeitbegrenzungen gibt. Die
kommentarlose Übernahme dieser Begriffe würde erneut dazu führen, dass nationale
Behörden JEDE Empfehlung eines Herstellers als „MUSS“ definieren (können). Eine im
Bereich des Luftsports seit Jahrzehnten übliche Überziehung von TBO unter konkreten
Bedingungen wäre damit ausgeschlossen. Nach dem gegenwärtigen Wortlaut müsste ein
Motor bei Erreichen einer empfohlenen Laufzeit in jedem Fall ausgetauscht werden. Hier
findet sich ganz konkret das Problem der Decision 2013/025/R wieder.
2. Die Forderungen nach der Führung der technischen Dokumentation nach der
Durchführung von Flügen ist für den Bereich des Luftsports, der ELA1- und ELA2-
Luftfahrzeuge weder sinnvoll, noch praktikabel oder in irgendeiner Weise der Flugsicherheit
fördernd. Für die Forderung der Aufzeichnung „nach jedem Flug“, insbesondere bei kurzen,
aufeinanderfolgenden Flügen, z.B. bei Ausbildungsflügen in der Platzrunde gibt es, soweit
keine technischen Probleme vorliegen, keinerlei Veranlassung die Angaben über Betriebszeit
und Landungen in die Bordbücher einzutragen.
Unter der Berücksichtigung der „Road Map for GA“ der EASA erwarte ich, dass alle
Luftfahrzeuge der Kategorie ELA1 uns ELA2 aus dieser NPA und der folgenden Decision
ausgenommen werden.
response
3. Proposed amendments — 3.1. Draft Opinion — 3.1.1. Annex I to Decision 2003/19/RM (AMC
p. 10
to Part-M) — Point M.A.305(a)

1. PARAGRAPH / SECTION THE COMMENT IS RELATED TO:
NPA 2014-04, page 10/44, point M.A.305(a)
2. PROPOSED TEXT / COMMENT:
Could the Agency clarify the term ‘certificate of release to service’ versus ‘authorised release
certificate’ (title of the EASA Form 1)?
Is the certificate of release to service:
– an authorised release certificate (i.e. a document),
– a declaration confirming that the maintenance work (to which the declaration relates) has
been completed in a satisfactory manner (i.e. a set of information),
– both, or
– something else?
3. RATIONALE / REASON / JUSTIFICATION:
The ToR related to this NPA specify that the rulemaking task will address issues related to
continuing airworthiness and maintenance records, and in particular the different
interpretations as to which documents are considered equivalent to an EASA Form 1.
On one hand, the points M.A.802(b) and 145.A.50(d) indicate the EASA Form 1, i.e. a
document, constitutes the certificate of release to service (for components). On the other
hand, the point M.A.801(f) and the AMC 145.A.50(b)2. seem to imply that the certificate of
release to service is a set of data.

In this context, one can ask what has to be “entered in the aircraft continuing airworthiness
records [….] in no case more than 30 days after the day of the maintenance action”. The
data, the documents, or both?
Could the following terms be proposed to help?
– The term ‘authorised release documents’ embraces documents confirming a certificate of
release to service. They include, amongst others, the operator’s technical logbook and the
EASA form 1 or equivalent.
– Within the context of maintenance, the ‘certificate of release to service’ is a declaration
confirming that the maintenance work to which it relates has been completed in a
satisfactory manner, either in accordance with the approved maintenance data and the
procedures described in the maintenance organization’s procedures manual or under an
equivalent system. The release procedures are described in the point 145.A.50, the point
M.A.801 for the aircraft and in the point M.A.802 for components.
response

NPA 2014-04, page 10/44, point M.A.305(a)
Could the Agency explain why the point M.A.305(a) has not been amended to take into
account the component certificate of release to service required by point M.A.802?
It is proposed to amend this point to read:
“M.A.305 Aircraft continuing airworthiness record system
(a) At the completion of any maintenance, the certificate of release to service required by
point M.A.801, M.A.802, or point 145.A.50 and the associated detailed maintenance
records shall be entered included in the aircraft continuing airworthiness records system
when they are required to be kept in compliance with (e). Each entry shall be made as soon
as practicable but in no case more than 30 days after the date the certificate of release to
service is issued day of the maintenance action for aircraft maintenance or for the
component’s installation on aircraft following the component maintenance.”
The amendment proposed by this NPA for the points M.A.305(e)2. and 3. refers to the
certificate of release to service, and in particular for maintenance performed on
components. So, how long is given to Part-M organisations to introduce in the aircraft
continuing airworthiness record system, the component certificate of release to service and
associated detailed maintenance records that contribute to demonstrate the aircraft
continuing airworthiness and the serviceability of both the operational and emergency
equipment?
At first glance, it may seem unnecessary to keep the certificate of release to service (and
related detailed maintenance records) associated with the off-wing maintenance of a given
component, because another certificate will be issued at component’s installation on
aircraft. Although components do not accumulate any flight hours or flight cycles when being
on ground, attention may need to be given to scheduled tasks where the accomplishment is
controlled in calendar time (hours, days, months, years). For some off-wing maintenance
tasks, the clock may run immediately after the authorised release document is signed. In
demonstrating compliance with the Aircraft Maintenance Programme, the date when the
authorised release document for off-wing maintenance is signed may be the reference to
calculate the next accomplishment of a maintenance task, not the date of the component’s
installation on aircraft. Further, the time between the signature of the certificate of release
to service and the component installation may be significant.
It is proposed to state “[…] entered in the aircraft continuing airworthiness record system.”
to be consistent with the point title (... record system). In addition, the next sentence begins
with “Each entry...” (consistency).
response
comment 210 comment by: Baines Simmons Limited

M.A.305 Aircraft continuing airworthiness record system
There is an inconsistency between the heading and the remainder of the rule texts, in that
the heading uses the term " ... record system" and the remainder of the text generally refers
to the "... records".
In our experience most (CAM) organisations do not adequately define the consituent parts or
structure of their record systems in their CAME or procedures. Inconsistencies such as
described do not help organisations (or individuals) understand the concept of a system of
records (as opposed to an IT system). We recommend that the term system is used
throughout to help reinforce the concept. In the interest of proportionality, the "system"
could consist of traditional log books for, e.g. NCO aircraft, or one or more computer
databases for, e.g. CAT aircraft.
M.A.305(a) Aircraft continuing airworthiness record system
In the first sentence the word "entered" has been replaced by "included", however the
second sentence still retains the word "entries". This is inconsistent.
May we propose the following, simplified sentence for M.A.305(a):
(a) As soon as practicable, but in no case more than 30 days after the day of completion of
any maintenance action, the certificate of release to service required
by point M.A.801 or point 145.A.50 shall be entered included in the aircraft continuing
airworthiness record system.
response
p. 10
to Part-M) — Point M.A.305(b)
comment 1 comment by: George Knight

This is a very disappointing proposal and very much against the spirit of more proportionate
regulation for General Aviation being talked about by EASA’s executives.
I am a sailplane pilot and instructor. I am also a sailplane towing pilot.
Sailplanes.
For my own sailplane I make up my sailplane’s logbook on a monthly basis to show the total
hours flown in the month and the numbers of launches that have taken place. For many
years, both before and after EASA maintenance rules, came into force this approach has
deemed to be satisfactory.
If my interpretation of the text
“(b) The aircraft continuing airworthiness records shall contain the following: 1. a record of
the date, total in-service life accumulated in flight hours and/or flight cycles and/or landings
and/or any other applicable parameter, for the aircraft, engine(s) and/or propeller(s) after
each flight;”
is correct the log book will, if this change is adopted, need an entry to be made for every
flight.
When one considers that, for training sailplanes, in particular, a great many flights may take
place in a single day and that when training for launch failures on the winch many of the
flights will have a duration of no more than one minute then this change will create a
ridiculous increase in the time and effort to enter each flight on a separate entry – possibly
more time updating the aircraft’s log book than it has flown.
It MUST be permitted to allow summary entries to be made in the logbooks of light general
aviation aircraft – in particular sailplanes where many very short flights take place.
There is absolutely no safety justification for requiring a separate entry after each flight or
even each day.
The regulation must permit summary entries to be made covering a period of up to one
month.
If EASA implements this rule then it is most unlikely that sailplanes will comply and log books
will cease to be accurate. A big negative impact on safety.
Please reconsider or provide and alternative solution for sailplanes.
Sailplane Towing
Sailplanes towing aircraft may make a great many flights each day – typically of 6 to 8
minutes in duration. The pilot is permitted to make summary entries for multiple flights that
take place without a break of more than 30 minutes in his/her log book.
It is nonsense for aircraft engaged in this type of operation to have to update the log books
with an entry for every flight as propose. There could be 30 or more flights (by several
different pilots) in a single day in one tug.
Please apply some common sense and allow summary entries covering multiple flights for
GA.
response
comment 15 comment by: Aviteh Ltd.

There is no clear definition of "flight hour" or "flight time" in the terms of airworthiness. The
definitions exist in FAA and Transport Canada regulations but not in EASA.
FAR Part 1, Section 1 - General definitions, provides the definition of "Time in service" as
follows:
"Time in service, with respect to maintenance time records, means the time from the
moment an aircraft leaves the surface of the earth until it touches it at the next point of
landing."
Canadian Aviation Regulations (CARs) Part I, Subpart 1 - Interpretation, gives similar
definition for "Air Time" as follows:
"air time means, with the respect to keeping technical records, the time from the moment
an aircraft leaves the surface until it comes into contact with the surface at the next point of
landing"
Most of the aircraft manufacturers give similar definition of "flight time" for the purpose of
continuing airworthiness management as above, i.e. "flight time" means only the time
aircraft is in the air and ground time doesn't count. On the other hand there are
manufacturers that don't give any definitions what "flight hour" actualy means and that
creates problem with different interpretations from civil aviation authorities.
New AMC to M.A.305(b) should be added with the definition of flight time as follows, or
similar:
"FLIGHT HOURS, FOR THE PURPOSE OF CONTINUING AIRWORTHINESS RECORDS,
MEANS THE TIME FROM THE MOMENT AN AIRCRAFT LEAVES THE SURFACE UNTIL IT
COMES INTO CONTACT WITH THE SURFACE AT THE NEXT POINT OF LANDING"
Adopting different defintion may have consequences in the case of import of aircraft from
USA or Canada. In that case imported aircraft may not have the correct number of flight
hours recorded.
response
comment 29 comment by: British Gliding Association

M.A.305 (b) 1
Add “as appropriate” after the sentence.
Rationale;
Many light aircraft do not have any cycle controlled items hence most operators do not
record flight cycles (landings). “as appropriate” was previously included in the rule and made
the paragraph workable.
response

M.A.305 (b) 1
There needs to be recognition that for ELA engine and propeller hours may be grouped into
weekly blocks and sailplanes flying hours and launches grouped into monthly blocks.
Rationale;
This is the established practice and an acceptable and less onerous method of recording with
no increased risk of components or lifed limited parts exceeding their life.
The majority sailplane operations tend to be many flights of short duration where the daily
totals are grouped and entered into the aircraft records in monthly blocks.
response

page 10/44
M.A.305 (b) 1.
"...after each flight" is not at all appropriate when it comes to series of flights in e.g.
helicopter operations or glider-towing operations, what the Agency asks for does not make
sense for flight schools where several flights of short duration are undertaken on the same
day.
Proposal 1:
Please add "...or series of similar flights."
Rationale:
This is more appropriate to the helicopter operators environment, to the mountain flyers
world, to the community of sailplanes operators and to parachute-jumpers operations. There
is no need for immediate detailed records when aircraft of relatively simple design are
involved, containing but very few life-limited items.
Many of our aircraft operate in a "low duration / high duty cycle environment. Do you really
consider it feasible and reasonable to fill-in logs between two sailplane-towing flights, two
parachute-dropping flights, two helicopter rotation when normally the engines are not
stopped? We think this is dangerous and simply is the opposite of what we are asked for,
which is safe conduct of flights.
Proposal 2 :
Please introduce the possibility of grouping flight hours for ELA aircraft engines in weekly
blocks, sailplanes flying hours in monthly blocks.
Rationale:
Considering the complexity of our operations we firmly believe that this method is sufficient
and fulfils the requirments.
We do not undertake CAT-like operations, our aircraft are of relatively simple design, most of
our operations take place in a VFR/VMC environment. We urgently ask you to accept these
facts.
response

NPA 2014-04, page 10/44, M.A.305(b)
Could the Agency clarify why the requirement of life recording is limited to products?
Should the paragraph (b) of the point M.A.305 read the following?
“(b) The aircraft continuing airworthiness records shall contain the following:
1. a record of the date, total in-service life accumulated in flight hours and/or flight cycles
and/or landings and/or any other applicable parameter, for the aircraft, engine(s), and/or
propeller(s) and/or any particular component after each flight; […]”
With regard to the term ‘total in-service life accumulated’, could the Agency clarify the origin
of life accumulation calculations? In other words, is the origin of calculations the date of first
ever flight/maiden flight, the date of entry into (revenue/operational) service, or any other
date?
For example, a life limitation may apply to some Auxiliary Power Unit (APU) rotating parts
(ref. EASA AD 2010-0079). In such a case, the life limitation may be measured in cycles of
APU usage. The requirement does not take into account the possible need for recording lives
that are asynchronous to those of products.

The origin of life accumulation calculations is not defined, although it is essential to manage
the aircraft continuing airworthiness (for example to schedule maintenance).
See also the comment on AMC M.A.305(b)1.
response

NPA 2014-04, pages 10/44, point M.A.305(b)
Point M.A.305(b)3. states “when required in point M.A.306 for commercial air transport or
by the Member State for commercial operations other than commercial air transport, the
operator’s technical log.”
Point M.A.306(a) states “In the case of commercial air transport, in addition to the
requirements of M.A.305, an operator shall use an aircraft technical log system […]”.
Could the Agency explain the reason for considering commercial operations other than
commercial air transport in point M.A.305, while this provision is not in point M.A.306?
If this consideration is justified, it is proposed to move it from point M.A.305 to point
M.A.306 to read:
[…]
(b) The aircraft continuing airworthiness records shall contain the following:
[…]
3. when required in point M.A.306 for commercial air transport or by the Member State for
commercial operations other than commercial air transport, the operator’s technical log.”
“M.A.306 Operator’s technical log system
(a) In the case of commercial air transport or when required by the Member State for
commercial operations other than commercial air transport, in addition to the
requirements of M.A.305, an operator shall use an aircraft technical log system […]”.
For sake of consistency and clarity.
response
comment 116 comment by: AS Miller
M.A.305(b) proposes a requirement that detailed records be added after every fight.
For sailplanes this is a ridiculous requirement.
There are no components or airworthiness events that require this information flight by
fight.
The recording burden would be intolerable in a gliding environment.
This proposal is in contravention of the EASA Board's approach to excessive GA burdens; the
Agency should review its procedures to find why such an inappropriate proposal got to the
NPA stage.
response
comment 156 comment by: Belgian CAA

M.A.305 (b) § 1. : To be complete and ensure correct traceability, it could be useful to
specify the record of the type of aircraft with registration marks, including the
engine/propeller serial number when applicable. It seems normal but to avoid confusion it
could be better to precise that information to ensure full traceability.
M.A.305 (b) § 1. : the reference to the “applicable parameter” is not in line with the
definition given in the “GM M.A.305 (1)”. Indeed, based on the content of this paragraph
it’s quite fully identical to the content of the “GM M.A. 305 (1)”. Perhaps this wording can be
cancelled from this article. Same remark for the “GM M.A.305 (9) (iv)” ; for “AMC
M.A.305 (c) 1. §a” and “AMC M.A.305 (c) 3 § (b)”.
response

Comment by European Gliding Union -
3.1 Draft Opinion 3.1.1, Annex 1 to Decision 2003/19/RM - Item M.A.305(b)
PROPOSAL
EGU might propose that M.A.305(b) be amended in several ways. The most simple is to add
final words to “.....after each flight or series of similar flights.”
The key issue here is that it is inappropriate and unnecessary to demand immediate detailed
records as applied to simple GA aircraft containing very few limited lifed items and operating
in low duration but high duty cycle operations. To better reflect this, one might further
embellish the amendment as follows: “..... at a cadence sufficient to safeguard life and time
controlled components.”
RATIONAL
The proposed text (“......after each flight.”) is inappropriate to light sport and GA aircraft
operating under Part M (or even under Part 145). Note that, in this NPA the Explanatory
Note UNKG-2007-091 states ‘...and Part M as necessary’, it was recognised that there may be
particular issues therein.
Light sport and GA aircraft typically carry out multiple flight each day quite possibly involving
multiple take-offs and landing. For these types of aircraft and operation flights are recorded
locally for log keeping and commercial records. Updating of maintenance records is generally
carried out at a lower cadence with complete accuracy. An ‘after each flight’ requirement is
inappropriate, uneconomic and irrelevant.
response
comment 187 comment by: UK CAA

Page No: 10
Paragraph No: M.A.305(b)
Comment: The use of “and/or” for each parameter in this paragraph implies that there is a
choice, such that they may not necessarily be recorded. By adding ‘as required’ then the
necessary parameters as dictated by the manufacturer for airframe, engine, propeller will be
recorded.
Justification: Clarity to ensure the correct and necessary information is recorded.
Proposed Text: “(b) The aircraft continuing airworthiness records shall contain the following:
and/or landings and/or any other applicable parameter, as required for the aircraft,
engine(s) and/or propeller(s) after each flight;”
response

M.A.305 (b), 1. "after each flight":
For Jumbo Jet ok.
For training impossible. Does it means that on a glider field "after each" winch launch all data
have to be collected? who will do this? and hopefully the authorities will check this "every
sunday on each" glider flield ...
response

M.A.305(b) Aircraft continuing airworthiness record system
We support the deletion of the requirement to use "log books", which for many
organisations, e.g. CAT operators of CMPA, have become an unacceptable administrative
burden, in that they are maintained for compliance reasons and rarely used to manage
continuing airworthiness. We do however believe that appropriately formatted and
completed logbooks would represent an acceptable means of compliance to this
requirement for, e.g. NCO aircraft.
M.A.306 Operator's Technical Log System
We have maintained for many years that the scope of applicability of M.A.306 is too narrow.
We believe all aircraft involved in any operation must have a Technical Log System in order
for the owner or CAMO to adequately manage the continuing airworthiness of aircraft.
In the interest of proportionality, we believe different formats could be described in
Acceptable Means of Compliance (AMC) and/or Guidance Material (GM).
response

This comment concerns § M.A.305 (b) to (d).
Although the purpose of paragraphs b, c, d are clear, DGAC finds the structure of elements
not so clear, with the choice of main verbs “include” or “contain”.
In addition, under “aircraft” continuing airworthiness records, it covers also of course, fitted
engines, propellers, and components. The definition of (CE)2042/2003 article 2
“components” include “engine” and “propellers” . Therefore, there is some confusion
reading paragraphs.
DGAC would suggest to reuse proposed terms that clarifies the details of the records, but to
merge the paragraphs (b) to (d) as follows and to add in the “introduction sentence of (b) the
fact all components of aircraft are also covered in the “aircraft continuing airworthiness
records”:
Proposed modification:
M.A.305
(a)….
(b) The aircraft continuing airworthiness records shall address the aircraft, its engines,
propellers and other components and contain the following:
and/or landings and/or any other applicable parameter, for the aircraft, engine(s) and/or
propeller(s) after each flight;
2. the data with the supporting detailed maintenance records to address the current:
a. status of airworthiness directives and measures mandated by the competent authority in

immediate reaction to a safety problem;
b. status of modifications and repairs;
c. status of compliance with the aircraft maintenance programme;
d. mass and balance report; and
e. status of deferred maintenance tasks and deferred defects rectification
3. The additional information with the supporting detailed maintenance records to address
specific components:
a. current status of life limited parts including the life accumulated by each affected part in
relation to the applicable airworthiness limitation parameter; and
b. current status of time controlled components, including the life accumulated by the
affected components in the applicable parameter, since the last accomplishment of
scheduled maintenance specified in the aircraft maintenance programme.
commercial operations other than commercial air transport, the operator’s technical log.
(c) and (d) are reserved.
(e) see further comments.
response

The new proposed requirement to have the regarding records written into the aircraft
continuing airworthiness records (ACAR) after each flight is not acceptable.
Especially in small aviation it is common practice to make multiple flights per day.
A sailplane or a small aeroplane could do easily more than 20 flights per day.
It is neither feasible nor acceptable to make an entry into whichever log after each flight in
such situations.
This could only come into the mind of persons familiar only with airline operations where
ither the number of flights is low per day or where you have the time and the personnel to
do such a thing.
We oppose this requirement.
An entry of all flights at the end of the day into an aircraft log book is common practice and is
also adequate. Nothing more.
response
The sailplane manufacturers have not the full overview of the proposed changes in M.A.305
because here in the NPA only the amended/modified sub-points are displayed.
This is not helping to not loose the overview.
Nevertheless we have the suspicion that with the proposed changes the clear definition that
an aircraft log book might be fully sufficient as an aircraft continuing airworthiness record.
If this is the case, then this should be rectified.
It is fully acceptable to the sailplane manufacturers, that perhaps for an airliner the aircraft
continuing airworthiness record could now be data on a hard drive or in the internet or
whatever modern means of data.
But for our communities it is important to have a clear sentence that a single old-dated
paper book called aircraft logbook is also sufficient.
The proposed mentioning of the aircraft logbook only in the AMC is not sufficient as
...some NAAs read and accept only what is found in the regulation
...some persons in Europe do not understand the English-only AMC
If such information is lost it will take not long until some not-understanding NAA demands
much more elaborated type of records (or even full internet access in a glider ;-) ).
response

In the GA environment and the glider community it is state of the art to enter the flights at
least once per day due to the fact that a lot of flights may be done during one day, especially
in the training organisations. Life limited components or time controlled components are
under control by periodic reviews. The need to enter the accumulated hours/cycles or
whatsoever for aircraft, engine and propeller (and other components ???) is not required
because in our environment only a limited number of components are affect by limitations
and these figures can be kept well under control by the means we have now. Collecting all
the data required by this NPA will be a lot of additional paperwork without any benefit - and
it will be paperwork because electronic means are not common here. The logbooks available
today don't even have the possibilty to enter these data.
So we do not aggree with this change and want to stay with the paperwork we have now in
use!
response

M.A.305(b)1.
Dieser Punkt ist für die Allgemeine Luftfahrt, speziell für den Bereich des Luftsports
überzogen. Er stellt eine unbillige Härte dar und hat weder Einfluss auf die kontinuierliche
Aufrechterhaltung der Lufttüchtigkeit, noch auf die Flugsicherheit.
Soweit keine technischen Besonderheiten oder Abweichungen vom Standard entstehen, ist
die Eintragung der akkumulierten Betriebszeiten (Zelle/Motor) und Landungen in die
Bordunterlagen nach jedem Flugtag völlig ausreichend.
Für die Feststellung der Restlaufzeit von Komponenten reicht es vollkommen aus, die
Restlaufzeiten von Komponenten einmal jährlich im Rahmen der Feststellung der
Lufttüchtigkeit festzustellen und diese Komponenten nur beim Unterschreiten einer
„kritischen Restlaufzeit“ einen verstärkten Kontrolle zu unterwerfen.
Vorschlag: Die Formulierung des „alten M.A.305(c)“ war völlig ausreichend:
„c) In die Luftfahrzeug-Bordbücher müssen, wie jeweils zutreffend, das Luftfahrzeugmuster
und das Kennzeichen, das Datum zusammen mit der Gesamtflugzeit und/oder den
Flugzyklen und/oder den Landungen eingetragen werden.“
response

We suspect that the formulation, well adapted to scheduled transport, may be burdensome
for the non scheduled community below
15'000/45'000 kg.
response

M.A.305 (b) 3.
Quote:
commercial operations other than commercial air transport, the operator’s technical log
endquote
Change into : for scheduled commercial air transport and leave the member state and ...
other than commercial air transport away.
As formulated it gives certain member states again a handle to regulate according higher
requirements.
response
comment 370 comment by: Oliver Garlt
The Agency proposes to update the aircraft continuing records after each flight.
This regulation is impractical to General Aviation.
Many flights in General Aviation are short traffic pattern / 5-minutes flights. To check life
limitations after those short flights for example to interrupt flight training – up to 20 times a
day - for updating the technical documentation is not necessary, but rather obstructive to
the air operations.
I propose to extend the period to the next day or the evening after a VFR flight day.
Aviation safety will not be affected in this case and the control of life limited parts and time
controlled components is still given.
Typical aircraft log books accumulate flight hours on every page and not after each flight.
Due to accurate preparation and the experience of the last seasons it is very predictable to
determine the moment of exceeding time limitations without accumulating flight time
several times a day.
response
p. 10-11
to Part-M) — Point M.A.305(c)
comment 5 comment by: ParTem Aviation

Item 5. - continuing airworthiness records should include status of deferred maintenance
tasks and deferred defects only. Rectification details should form part of the the
maintenance records.
response
comment 285 comment by: DAC Luxembourg

COMMENT DACL-2014-04-05
Modify points M.A.305 (c) 2; M.A.305 (e) 2 and corresponding AMC M.A.305 (c) 2 and GM
M.A.305 (c) 2 by replacing the wording “modifications” by “changes to type design” and
suppression or clarification of the GM M.A.305 (c) 2.
Reason/Justification:
The terminology “modification” introduces the need for a definition, which does not exist.
The proposed M.A.305 (c) 2 (ii), while using the wording “modifications”, referred to
M.A.304, which itself refers to data approved under Part 21 Subpart D “Changes” (And
Subpart M “Repairs”). This change to the type design is a clear concept that can be used
instead of modification.
On the other hand, and following GM M.A.305 (c) 2, the status of modifications embodied
includes the list of installed components. This concept is almost linked to the “configuration”
of the aircraft, not to the changes (with SB, STC, minor change, etc.) that could have been
made on the aircraft / components. A clarification is needed. See also Annex I to Decision
2013-005R and its definition of Repair status as a point of comparison:
Repair status means a list of:
- the repairs embodied since the original delivery of (and still existent upon) the aircraft /
engine / propeller / component; and
- the un-repaired damage/degradations.
response

Das AMC M.A.305(c)3 beschreibt den „Status der Übereinstimmung mit dem
Instandhaltungsprogramm“ näher gun gibt auch Hinweise zur Umsatzung.
Vor dem Hintergrund der zu erwartenden Selbsterklärung von Instandhaltungsprogrammen
durch Eigentümer/Halter für ELA1-Luftfahrzeuge und weiterer Vereinfachungen für die
Allgemeine Luftfahrt erscheinen die Regelungen für diesen Punkt für die betreffenden
Luftfahrzeuge zu restriktiv.
Wer stellt unter diesen Umständen den Status fest? Zu welchem Zeitpunkt? Wie wird dieser
dokumentiert?
Welche Auswirkung hat eine Abweichung bei der Feststellung durch Dritte gegenüber der
eigenverantwortlichen Erklärung des Eigentümers/Halters bei nicht gewerblich genutzten
einfachen Luftfahrzeugen?
Die EASA sollte die betroffenen Luftfahrzeuge aus der Änderung bis zur abschließenden
Klärung im Zuge der Vereinfachungen für die Allgemeine Luftfahrt ausschließen.
response
p. 11
to Part-M) — Point M.A.305(d)
comment 12 comment by: AOPA-Sweden

(d) The aircraft continuing airworthiness records shall include...
1. current...
2. (add): For commercial air transport only, current status of time controlled components,
including... ... maintenance programme.
The definition added in GM MA 305(d)(2)(c) for the term ”Time Controlled Components” will
otherwise make it neccesary to break out all inspections for wear and condition etc of
bearings, joints etc, etc currently listed in the DAH inspection lists and list them separately
with individual times. This is totally unacceptable for GA and would impose another
bureaucratic burden that the GA market cannot take. Nor are there any safety gains to be
had, rather on the contrary as valuable resources are spent on meaningless paper exercises.
Note that "operations other than CAT for which the authority requires a certificate", should
also be extempt as the ATO:s operating GA-type aircraft would otherwise be similarly
burdened.
response

M.A.305 (d) 1 and 2
These statements should only be applicable to CAT.
Rationale:
ELA and sailplane components are monitored at scheduled maintenance intervals, typically
annual or 100 hour check and at airworthiness review, and those whose life will be exceeded
before the next scheduled maintenance are attended to or highlighted to the maintenance
manager/owner. Continuous monitoring is inappropriate and too onerous for most private
aircraft owners.
response

page 10/44
We think M.A.305(d) should only be applicable to CAT.
Proposal:
Restrict this provision to CAT.
Rationale:
Continuous monitoring is much too onerous for privately owned and operated aircraft, it
does not increase safety, it only increases flight-hours-costs because of higher maintenance
administration burdens.
response

- M.A.305 (d) and M.A.503 : if the wording “service life limited” is to be changed with this
NPA, it is important to ensure harmonization in the whole regulation. Indeed, for example,
the “M.A.504 (a) 1.” refers to “service life limit”. Same remark for “Appendix III to AMC
M.B.303(d)” that refers to “Ultimate service life” and the Appendix XIII to M.A.712 (f) which
refers to "life limited components".
-M.A.305 (d) § 2. : it will be clearer to change “….last accomplishment of scheduled
maintenance specified in the aircraft maintenance programme.” By “….last
accomplishment of the corresponding scheduled maintenance task specified in the aircraft
maintenance programme.” It’s just to reduce as more as possible any risk of erroneous
interpretation.
response

3.1 Draft Opinion 3.1.1, Annex 1 to Decision 2003/19/RM - Item M.A.305(d) (1 and 2)
While these clauses may be appropriate for CAT, the resources necessary for continuous
monitoring are not feasible or realistic for Sport/GA. This should be clarified.
RATIONAL
In Sport/ GA, scheduled maintenance is a assured/carried out at frequent intervals as
defined by the TC holder. While the existence of lifed items is not the norm, when they arise,
their needs can readily be accommodated within a scheduled and customized maintenance
programme. Practically, GA airframes are not necessarily operated in close proximity to
commercial maintenance organizations and requirements for continuous monitoring are not
necessary and would be uneconomic for GA operators.
response

The change proposed in Para.2 does not read particularly well. Can you consider wording
similar to Para. 1 - amend to "current status of time controlled components, including the life
accumulated by the affected components in RELATION TO the applicable parameter……..."
response

Der Versuch der Einführung der Definition von „lebenszeitbegrenzten Bauteilen“ und
„laufzeitkontrollierten Komponenten“ führt im Falle von ELA-Luftfahrzeugen nicht wirklich
dazu, Missverständnisse zu vermeiden.
TBO von Motoren werden ohne weitere Erläuterung nach einschlägiger Erfahrung durch
Behörden ohne Weiteres als „lebenszeitbegrenzt“ eingestuft.
Die übliche Praxis, "On-Condition" auch lebenszeitbegrenzte Bauteile nach dem ablauf der
Laufzeitbegrenzung weiter zu betreiben ist in der Allgemeinen Luftfahrt unter konkreten
Voraussetzungen durchaus üblich.
Die vorliegende Definition taugt in erster Linie nur für die Klarstellung der technischen
Aufzeichnungen bei kommerziell genutzten Luftfahrzeugen und sollte deshalb nur auf diese
beschränkt werden.
response
comment 365 comment by: ASD MRO Working Group

Re M.A.305(d) there are varying NAA interpretations to-day as to what records constitute
the ‘status’ of Life Limited Parts or Time Controlled Components. Is the ‘status’ a summary
document only or does the owner/operator have to keep the last installation record and
Form 1 (as applicable) for these LLPs and Time Controlled Components to support the
‘status’ document referred to?
response
p. 11-12
to Part-M) — Point M.A.305(e)
comment 3 comment by: Ken Mutton (CityJet)

Can further clarification be given as what is the 'last entry'. There are differing
interpretations as to what this is as follows:
 Last Entry - this is the last entry into the aircraft technical log prior to aircraft's
permanent withdrawl from service. Therefore all records for the aircraft technical log must
be retained for three years (36 months), following the withdrawl of the aircraft from service.
or
 Last Entry - this the is the latest (or current) entry into the aircraft technical log.
Therefore technical log records will be retained for 3 years following the entry being made
into it.
Ken Mutton - CityJet
response

MA 305 (e) 2 (ii):
The requirement for detailed maintenance records should be limited to 2003 and onwards,
as before that date national regulations applied and those may have had less stringent
criteria for records keeping, especially for repairs and modifications.
If not changed, the NPA text here is a potential cause for more or less permanent grounding
of older GA aircraft in some countries.
response
comment 18 comment by: AIR FRANCE

2. General data (i) :
 Is an AD status can be considered as relevant "Detailed maintenance record"
demonstrating compliance with AD ?
 Does it mean that "Dirty finger print" is not more considered to be kept as
subtantiating data to demontrate compliance ?
3. Data specific to certain components (i)
 Could you add the notion of "Applicable airworthiness limitation parameter" to be in
coherency with § MA.305 (d) 1 ?
response

M.A.305 (e) 1
It should be specified that a Technical Log is only applicable to Commercial Air Transport.
response

M.A.305 (e) 2 and 3
1/ 36 months retention for all records should be retained.
Rationale:
24 months is too short a time and important information could be lost. 24 months is less
than a “Controlled Environment” Airworthiness Review/ARC issue period and could impede
the document review this increasing the risk of an inconclusive review.
2/ Guidance material is required to recommend retaining useful maintenance records for
longer than the minimum time.
Rationale:
It can be very helpful in troubleshooting or defect investigation if previous records are
available. This can highlight issues where a defect or problem is reoccurring and may indicate
that a design change is warranted or poor standard components are being supplied.
Disposing of the records after 24 months or when repeated means that opportunity is lost.
response

Page 11/44
Proposal:
M.A.305(e) should be applicable to CAT operations only.
Rationale:
Our community does not need a "system" to satisfy the needs of the competent authority.
For CAT operators such a system might be helpful, to our operations, however, such a system
will not produce any gain in flight safety, it only will add costs to our flying.
response

page 11/44
M.A.305(e)
2. General data
and 3. Data specific to certain components
Proposal:
We propose to stay with the 36 months of (e) 1.
Rationale:
In doing so the requirements are identical and fit with the 36 months interval when it comes
to the issue of an ARC.
Considering the average age of around 40 years of SEP aircraft it would probably be useful to
establish some guidance on how relevant maintenance records should be retained for even
longer periods to facilitate troubleshooting and more complex maintenance tasks.
response

NPA 2014-04, page 11/44, point M.A.305(e)1.

“1. Operator’s technical log system:
tThe technical log or data equivalent in scope and detail contained in the information
technology system, corresponding to the period starting 36 months prior to the last entry
latest flight shall be retained.”
A carriage return has been introduced for consistency with the way the other bullet points
are organised.
The wording “prior to the last entry” seems inappropriate since it could imply that some or
all the entries made when or before placing an aircraft into storage conditions for a long
duration (e.g. >36 months) could be disposed before the aircraft undergoes re-
commissioning. The wording “the period starting” indicates the entries logged after the
latest flight are also to be kept.
response

NPA 2014-04, pages 12/44, point M.A.305(e)2. and 3., and (e)4.(iii)
Point M.A.305(e)2. and 3. refer to “the certificate of release to service” (singular form). Point
M.A.305(e)4.(iii) refers to the “most recent certificate of release to service” (singular form).
Does it mean that only one certificate of release to service for all accomplished maintenance
activities (the one covering the most recent AD, modification, repair, or maintenance visit?)
is to be kept?
For sake of understanding/clarity.
Point M.A.305(e)2. and 3. refer to “detailed maintenance records”.
response

NPA 2014-04, pages 12/44, point M.A.305(e)2.(ii)
Point M.A.305(e)2.(ii) refers to “the applicable data in accordance with M.A.304”.

Could the Agency clarify the meaning of “applicable” in this wording?
Does it mean the Agency expects* that the person or organisation responsible for the
aircraft continuing airworthiness keeps the certificate of release to service and detailed
maintenance records resulting from the application of modification and repair data
complying with point M.A.304?
* for current modifications and repairs to the aircraft, engine(s), propeller(s) and any
component subject to airworthiness limitations
The wording of point M.A.305(e)2.(ii) has been found confusing. For sake of
understanding/clarity.
response

NPA 2014-04, pages 12/44, point M.A.305(e)4.
Could the Agency clarify the reasons why the point M.A.305(e)4. does not take into account
components (e.g. an engine) permanently withdrawn from service?
Should the introductory sentence read the following?
“4. Retention periods when the aircraft or a component, as appropriate, is permanently
withdrawn from service: […]”
It is not clear why component data/reports/statuses are to be kept for 24 months when the
(affected) components are permanently removed from service at the same time as the
aircraft (because they are fitted to the aircraft) and not when the same components are
permanently removed from service, but separately.
response

NPA 2014-04, pages 12/44, point M.A.305(e)4.
Could the Agency clarify the reasons why the operator’s tech log has not been taken into
account in the point M.A.305(e)4.?

Should this point read the following?
“(iv) the technical log or data identified in M.A.305(e)1. shall be retained for at least 24
months.”
It is not clear why the operator’s tech log data are not to be kept like the other
data/reports/statuses, i.e. for 24 months after an aircraft is permanently removed from
service. It gives the impression that operator’s tech log data are less important than others
and therefore can be destroyed on the day the aircraft is permanently removed from service.
response
comment 115 comment by: Francis Fagegaltier Services

In the proposed M.A.305 (e) 4 (retention periods), unless this is corrected elsewhere in the
proposals but not identified by the commenter, apparently it is assumed that when an
"aircraft is permanently withdrawn from service" the engines are also withdrawn from
service. This is likely to be a false assumption : an engine may be re-used in another aircraft.
The new text should differentiate the cases of engines which are withdrawn from service
together with the aircraft and engines which are re-used in another aircraft.
response
comment 141 comment by: CAA-NL

The retention period for maintenance data in the current Part M was specifically set at a
period until the data was superseded by new equivalent information but not less than 36
months. This was done in the EASA committee to guaranty the availability of all the data
between 2 full airworthiness reviews in a controlled environment which is 3 years. The
retention period after permanent withdrawal from service was less to minimize the
administrative burden. As we think these arguments are still valid we oppose the retention
period of 24 months and suggest a reinstatement of 36 months when in service. We agree
with a harmonization if needed for consistency but on 36 months.
response

- M.A.305 (e) § 1. : it could be useful to complete the sentence with : “…if there is no record
in this system requiring an additional period of retention as defined in the PART-M
regulation.” Indeed, for example, the tech log can contain some “release to service” for
certain repairs or maintenance actions or AD that must be kept to ensure traceability.

- M.A.305 (e) § 2. (i) and M.A.305 (e) § 2. (iii) and M.A.305 (e) § 3. (ii) : the introduction
of a calendar limit of 24 months seems not really necessary. Indeed, as soon as, it is
specified that this kind of record must be kept until it is replaced by equivalent information
in scope and detail, we think it’s sufficient. It is not necessary to cumulate records for a
same task ; we think that there is no safety risk as soon as we have the records of the last
performance of task.
-M.A.305 (e) § 2. (ii) : we consider that this article should be revised to remove the
limitation to “airworthiness limitations”. The records related to modifications and repairs
are important in other cases than only “airworthiness limitations” items. Indeed, if there are
scheduled maintenance requirements or hard time requirements, it is necessary to ensure
the traceability of those cases also. In fact, it seems this article can be already covered by
the article M.A.305 (e) 2. (iii). Indeed, the airworthiness limitations, modifications and
repairs are included in the maintenance required for the continuing airworthiness by
definition and all is covered by the maintenance program also.
- M.A.305 (e) § 3. (i) : this paragraph seems already covered by the article M.A.305 (d).
-M.A.305 (e) § 3. (ii) : it could be more appropriate to replace “…last accomplishment of
any scheduled maintenance and any subsequent unscheduled maintenance,….by another
scheduled maintenance of equivalent scope…” by “…last accomplishment of any
scheduled maintenance or other maintenance required,….by another maintenance of
equivalent scope…” to cover scheduled maintenance and other type of maintenance, as it is
done in “M.A.305 (e) § 2. (iii)”
response
M.A. 305 (e) 2.(ii)
I think the rentention period for the records should be mentioned as a "reminder", e.g. 24
months after permanently withdrawn from service
response

3.1 Draft Opinion 3.1.1, Annex 1 to Decision 2003/19/RM - Item M.A.305 (e) 2 and 3
Records should be retained for at least the period of ARC validity in the 'Controlled
Environment' (ie. 36 months)to enable proper review. It should be recommended (but not
mandated) that owners should retain maintenance records with the aircraft whenever these
might have a bearing on future maintenance actions.
RATIONAL:
Maintenance records are vital to the cost effective maintenance of any airframe, no matter
how large or small. This is of particular concern when the ownership or stewardship of an
airframe may change hands several time, such as is the case in Sport/GA. This is also key
information for any engineer and ARC reviewer, in tracing the origin of any parts identified as
faulty.
response

Page No: 12
Paragraph No: M.A.305(e)3
Comment: In accordance with Part 21.A.307(c) for ELA1 and ELA2, aircraft components
without an EASA Form 1 can be fitted to an aircraft. The paperwork that identifies which
components have been fitted should be kept as part of the aircraft records until such time
the component is replaced with one that has an EASA Form 1.
Justification: Ensures that the records include these items that are specific to these class of
aircraft.
Proposed Text: Add new paragraph (iii):
“The certificate of release to service and owners acceptance statement for any component
that is fitted to an ELA 1 or ELA 2 aircraft without an EASA Form 1 in accordance with Part
21.A.307(c).”
response

M.A.305(e)4
An explanation/definition of ”permanently withdrawn from service” would be helpful.
response
comment 208 comment by: Martinair
Please can you explain what the definition of permanently withdraw from service is
Do I have to think about demolition, permanent parking or hand over to another operator
response

Comment 1
In the following paragraph (e) it is unclear as to what "... prior to the last entry shall be
retained." is intended to mean. The Technical Log System is an on-going record. The first
entry would be the entry made near to the aircraft's first operation where M.A.306 applies,
and the last entry would be where it is exported from the EU, or withdrawn from service, etc.
We believe the intent of the requirement is to keep a rolling 36 month's worth of data at any
point in time. In other words, at the 01 June 2014 the records should include all technical log
documents/data dating back to 01 June 2011.
Hence we recommend the requirement should read as follows:
"(e) The owner or operator shall ensure that a system has been established to
keep the following documents and data for the periods specified in a form
acceptable to the competent authority:1. Operator’s technical log system: the technical log
or data equivalent in
scope and detail contained in the information technology system
corresponding to the 36 months prior to the most recent entry shall be
retained."
Comment 2
In paragraph "2. General data" the following wording appears " ... until such time as the
information contained therein is superseded by
new information equivalent in scope and detail but not less than 24 months." It is not clear
how this should be interpreted. Each inspection or check instance potentially identifies
defects and as a result the defect must be recorded together with the corrective actions
performed. Is the intent to retain the data, e.g. task card, recording the performance of the
inspection only, until the same inspection is subsequently repeated as per the Maintenance
Programme? We consider this lack of clarity could allow/cause operator's to dispose of
valuable inspection and/or defect data thereby potentially compromising on-going reliability
analysis. We believe this philosophy to be flawed and this text should be deleted in each
case.
Comment 3
There does not appear to be a requirement to keep CRS and detailed maintenance records in
relation to defect rectification. "other maintenance required for continuing airworthiness"
should include this, but the definition in the GM does not sepcifically include this. We feel
this is a significant omission and must be included as follows:
(iii) the certificate of release to service and detailed maintenance
records of all scheduled maintenance, defect investigation and rectification, or other
maintenance
required for continuing airworthiness in respect of the aircraft,
engine(s), propeller(s), as appropriate;
Comment 4
We support the remainder of the changes made to M.A.305 Aircraft continuing
airworthiness record system in that the introduce greater clarity and consistency to the rule.
response

Para 1. Corresponding requirements to retain maintenance records in M.A.305 have been set
at 24 months - is the intention to keep the operator technical log data retention at 36
months?
Para 3. Data specific to certain components, Para. (i) - Will further guidance (GM M.A.305
aside) be provided as to what constitutes "an in-service history record" for a component and
what entities can compile such a record in an acceptable manner. Also can clarification be
included as to the situation with Non Incident / Non-Accident Statements which are quite
often requested by various parties and their overall standing from an aircraft continuing
airworthiness records perspective.
Para. 3(ii) - The fact that retention of detailed maintenance and CRS records for life limited
parts beyond 24 months is not required in the circumstances permitted by this paragraph is
somewhat contradictory to the guidance provided in GM M.A.305 (9) where it is requested
that the in-service records documenting each time a life limited part is placed in service or
removed from service are retained.
response
comment 226 comment by: AEA

M.A. 305 (e) 2 (ii): …..”current” mods and repairs.
Comment: What is meant with “current”?
response

M.A. 305 (e): requirement to keep operators Tech Log system recordings for 36 months.
Comment: Other paragraphs in M.A. 305 (e) on page 11 and 12 refer to 24 months. This is
inconsistent with the recently adopted approach to keep records in Part M and Part 145 for
36 months in order to align to record retention period for the ARC inspection.
response

M.A. 305 (e) 3 (i)An “in-service history record” for each…..
Comment: Please specify what this record should contain
response

The purpose of this paragraph is to provide with a time period to keep the various
documents, but there is none for paragraphs (e) (2) (ii) and (e) (3) (i).
The paragraphs 1, 2, 3 are therefore a list of documents, and within the paragraph, a time is
specified. For item 4, it starts for a “retention time” for a list of “documents”. For consistency
of the overall paragraph (e), it is proposed to rewrite the fourth bullet.
M.A.305 e) The owner or operator shall ensure that a system has been established to keep
the following documents and data for the periods specified in a form acceptable to the
competent authority:
1. Operator’s technical log system: the technical log or data equivalent in scope and detail
contained in the information technology system corresponding to the 36 months prior to the
last entry shall be retained.
2. General data:
(i) the certificate of release to service and detailed maintenance records demonstrating
compliance with airworthiness directives and measures mandated by the competent
authority in immediate reaction to a safety problem applicable to the aircraft, engine(s),
propeller(s) and components fitted thereto, as appropriate, until such time as the
information contained therein is superseded by new information equivalent in scope and
detail but not less than 24 months;
(ii) the certificate of release to service and detailed maintenance records demonstrating
compliance with the applicable data in accordance with M.A.304 for current modifications
and repairs to the aircraft, engine(s), propeller(s) and any component subject to
airworthiness limitations, until such time as the information contained therein is superseded
by new information due to further modifications or repairs; and

(iii) the certificate of release to service and detailed maintenance records of all scheduled
maintenance or other maintenance required for continuing airworthiness in respect of the
aircraft, engine(s), propeller(s), as appropriate, until such time as the information contained
therein is superseded by new information equivalent in scope and detail but not less than 24
months;
3. Data specific to certain components:
(i) an in-service history record for each life limited part from which the current status of
compliance with airworthiness limitations can be determined, until such time as the life
limited part is removed from the aircraft;
(ii) the certificate of release to service and detailed maintenance records for the last
accomplishment of any scheduled maintenance, and any subsequent unscheduled
maintenance, on all life limited parts and time controlled components until the scheduled
maintenance has been superseded by another scheduled maintenance of equivalent scope
and detail but not less than 24 months;
4. Retention periods when The following specific data for at least 24 months after the aircraft
is permanently withdrawn from service:
(i) the data required in M.A.305(b)1 in respect of the aircraft, engine(s), and propeller(s) shall
be retained at least 24 months;
(ii) the last effective status and reports identified in M.A.305(c) and (d) shall be retained for
at least 24 months;
(iii) the most recent certificate of release to service and detailed maintenance records
identified in M.A.305(e)2 and (e) 3 shall be retained for not less than 24 months.
response

Further to our previous comment #265 the terms “the most recent certificate” is unclear. Do
we mean the latest of all release certificates required to be archived under the referenced
paragraphs (which means only one certificate) or the most recent for each of the
requirements, so therefore, possibly several release certificates?
Please revise the proposed text according to the answer to this question.
response

Can we have a defitinion of "permanently withdrawn from service"? How can we deal with
long storage period? do we consider the de-registration? other? In fact, how long can we
bring parts from an aircraft on unground until it is considered as withdrawn from service?
response
comment 307 comment by: IATA

Inconsistencies regarding the record keeping period; in some cases it is 36 months and in
others 24 months. This is also inconsistent at other parts of the NPA.
Consideration may be given in keeping records for certain periodic events for a period
equivalent to the maintenance cycle.
response

Point M.A.305(e) item (4)(i) “shall be retained…” should be “shall be retained for…”
response

According to M.A.305 (e) 3. (ii) it seems that a simple FORM-ONE is no longer sufficient as a
maintenance record for components? To what extend maintenance records are required to
be kept by the owner? Again here is asked for additional paperwork without any benefit. The
owner and even the ARS are not in a position to check if the maintenance at component
level has been done properly - this is the responsibility of the organisation issueing the
FORM-ONE!
We disagreed with this requirement!
response

Diese Neuformulierung des ehemaligen M.A.305(h) birgt eine zusätzliche Verschärfung,
indem sie den Grundsatz der Zweckmäßigkeit nicht mehr berücksichtigt.
Die Klarstellung der EASA, in welchem Umfang Freigaben durch den
Eigentümer/Halter/Operator zu führen und aufzubewahren sind, wurde im „alten
M.A.305(h)“ ausreichend dargestellt.
response

M.A.305(e) could benefit from a table being included (in AMC or GM?) to clarify the data
retention requirements of the owner/operator. For example a table listing Records Category;
Type of Records to be Retained and Retention Period would clarify matters considerably. This
paragraph is ‘silent’ with respect to records retention requirements for Condition Monitored
(CM) Components. What records (if any) must be retained for CM Components? Does the 24
month rule apply? Is it necessary for the owner/operator to retain the installation record and
Form 1 (as applicable) for a CM Component and for what period?
response
p. 12
to Part-M) — Point M.A.305(g)

NPA 2014-04, pages 12/44, point M.A.305(g)
[…]
(g) All entries made in the aircraft continuing airworthiness records system […]”.
For consistency between the point M.A.305 title and the paragraph text.
response

Point 3.(i) - IATA has worked with industry stakeholders on a draft template to define such
contents and can share the contents of the template to be used as the industry “standard”.
response
p. 13

Although it is not in the EASA proposal we suggest an amendment to M.A.307(a)
Proposal:
(a) The owner or operator shall ensure when an aircraft or a component is permanently
transferred from one owner or operator to another that the M.A.305 continuing
airworthiness records and, if applicable, M.A.306 operator’s technical log are also
transferred.
Explanation:
It is essential that in case of an ownership change of a component, the new owner is in full
possession of all relevant airworthiness history data. For this an amendment M.A.307 is
proposed.
response

M.A.306 Operator's Technical Log System
We have maintained for many years that the scope of applicability of M.A.306 is too narrow.
We believe all aircraft involved in any operation must have a Technical Log System in order
for the owner or CAMO to adequately manage the continuing airworthiness of aircraft.
In the interest of proportionality, we believe different formats could be described in
Acceptable Means of Compliance (AMC) and/or Guidance Material (GM).
response
p. 13
to Part-M) — Point M.A.503

NPA 2014-04, pages 13/44, points M.A.503(a) and (c)
Could the Agency explain why no flexibility is given to manage recommended limitations?
They are treated in the same way as mandatory ones. Or, would there be a wrong use of the
term ‘approved’ in the wording ‘approved limit’?
It is proposed to amend these points to read:
“(a) Installed service life limited life limited parts and time controlled components shall not
exceed the approved service life limit mandatory airworthiness limitations as specified in
the approved aircraft maintenance programme and airworthiness directives, except as
provided for in point M.A.504(c).
(b) […]
(c) At the end the approved limit service life, tThe installed time controlled components
and life limited parts must be removed from the aircraft for maintenance, or for disposal in
the case of life limited partscomponents with a certified life limit, respectively, no later than
the mandatory airworthiness limitations as specified in the approved aircraft maintenance
programme and airworthiness directives.”

In accordance with the item 7 of point M.A.301, Operators may want to include in the
embodiment policy some flexibility provisions for limitations recommended by Design
Approval Holders. This would not jeopardize the aircraft airworthiness (as such limitations
are recommended, not mandatory), but could prevent an unnecessary burden on aircraft
operations. While the case of mandatory airworthiness limitations is not disputed, there
should be some flexibility for recommended limitations.
With regard to the term ‘limit’ (singular form), the maintenance tasks applicable to a
component may be of different natures: e.g. a landing gear sliding tube may need to be:
– Periodically inspected to an appropriate standard in order to determine whether it can
continue in service (‘on condition’ maintenance process related part); and
– Permanently removed from service no later than a specified life limitation (life limited
part).
Therefore, a component may be affected by more than one limit (e.g. one in flight hours and
one in flight cycles) and more than one limitation (e.g. a life limitation and a limitation for
inspection). It is therefore recommended to refer to ‘mandatory airworthiness limitations’
(mandatory airworthiness limitations are approved in accordance with design-related
regulations).
response

NPA 2014-04, page 13/44, point M.A.503(b)
Could the Agency clarify what is expected from the person or organisation responsible for
the continuing airworthiness of the aircraft as a result of the point M.A.503(b)?
It is proposed to delete the point M.A.503(b).
The limitation parameters are defined by the relevant Design Approval Holder and approved
by the Agency at the same time as the limitations. The person or organisation responsible for
the continuing airworthiness of the aircraft has no control over this matter.
Further, the point M.A.503(b) provides only a partial list of usage measurement units for
limitation parameters: e.g. APU cycles are not listed although the EASA AD 2010-0079
imposes a life limitation expressed in this usage measurement unit.
response

- M.A.503 and M.A.504 : in the M.A.503, there is a reference to “approved limit” whereas in
the M.A.504, the reference is “mandatory limitation”. It could be useful to harmonize
terminology to avoid confusion. It is important to pay attention to the applicable limit we
consider. Indeed, for example, for several components, the TC holder’s refer to the vendor
recommendations and in the vendor recommendations, there is often the use of wording
“recommended maintenance” and not “mandatory maintenance”. In these circumstances, it
is important to clarify the situation because in certain case a recommendation can be
understood by certain persons as not to be done without other approach. Same remark for
the “appendix II to M.A.201 (h) (1), § 2.11” and for “AMC M.A.504 (c)”.
response

Page No: 13
Paragraph No: M.A.503(a)
Comment: The life limit for life limited parts is not necessarily mandated by an Airworthiness
Directive, for example it can be through the Type Certificate. Reference to point M.A.504(c)
should be removed. UK CAA comment made against M.A.504(c) refers.
Justification: Ensure clarity for the requirements for components depending on the type of
component.
Proposed Text: “(a) Installed life limited parts and time controlled components shall not
exceed the approved limit as specified in the approved maintenance programme and
airworthiness directives, and other mandatory Airworthiness’ Requirements, except as
provided for in point M.A.504(c).”
response

M.A.503 reworded as follow
(a) Installed life limited parts shall not exceed the mandatory limit as specified in the
approved maintenance data and airworthiness directives, except as provided in point
M.A.504(c).
(b) Installed time controlled components shall not exceed the limit as specified in the
maintenance programme.
(c) The limits are expressed in calendar time, flight hours, landings or cycles, as appropriate.
(d) At the end of the mandatory limits, the life limited parts must be removed from the
aircraft for disposal, except as provided in point M.A.504(c).

(e) At the end of the limit, the time controlled components must be removed from the
aircraft for maintenance.
The wording used in the original proposition does not clearly segregate the mandatory life
limits of the life limited parts (ALI/CMR approved under the authority of the State of Design)
from the limits of the time controlled components (recommendations of the DAH approved
through the AMP). It therefore introduces confusion with the definition provided in GM
M.A.305 (i.e. “mandatory life limitation”).
The proposed text splits both type of components and places them in line with the processes
for the approval of the maintenance limits in Part 21 (Through the certification process) and
Part M (Through the maintenance programme approval). The mandatory limit of life limited
parts is then clearly highlighted by the "mandatory limit" terminology. This way to define
the different parts / components avoids any ambiguous understanding of both definitions
and improves the quality of the readability.
response

DGAC would recommend using "aircraft maintenance programme" instead of "approved
maintenance programme". This term is already used in GM MA305 definitions of "life limited
parts" and "time controlled components". In addition, it is consistent with the opinion
10/2013 and the introduction of "self-declared maintenance programme" as an alternative
to “approved maintenance program” for some category of aircraft.
response

Item M.A.503 (c) - Beginning should read: “At the end of the approved….”
response

page 13/44
M.A.503
We propose not to change the term "service life limited" components.
Rationale:
Considering the effects of such a change on all publications we do not find any return on
investment. Think of all the books/texts/publications competent authorities will want us to
change "in order to be consistent with..." as they will say.

Just having experienced what it meant for us to change from an FTO to an ATO in working
hours and money, you better do insist on this proposal which is not at all relevant to the
safety of flight.
The actual term used and the new one are anyhow not correct as there never was life in a
technical part, and it never will be. Using the term "utilisation" or "application" would in our
view be more correct.
response

At the end of the approved .....
response

Die EASA sollte klar herausstellen, dass M.A.503 NICHT für Empfehlungen der Hersteller für
Laufzeitbegrenzungen von Bauteilen und Komponenten gilt.
response
p. 14

NPA 2014-04, page 14/44, point M.A.504
It is proposed to modify the point M.A.504(a) to read:
“(a) A component shall be considered unserviceable in any one of the following
circumstances:
1. expiry of the service life limit as definednon-compliance with the instructions specified
in the approved aircraft maintenance programme;
[…]”.
As already explained, the maintenance tasks applicable to a component may be of different
natures: e.g. a landing gear bogie beam may need to be:
– Inspected to an appropriate standard within a mandatory periodic time-frame (e.g. EASA

AD 2013-0267R1) in order to determine whether it can continue in service; and
– Permanently removed from service no later than a specified mandatory life limitation.
Therefore, for example, a component may be unserviceable because a mandatory inspection
has not been performed within the mandatory airworthiness limitations as specified in the
approved aircraft maintenance programme (including airworthiness directives), even if the
total in service life accumulated by the component has not reached the mandatory life
limitation.
And the term service life limit is a question item in the ToR.
response

Page No: 14
Paragraph No: M.A.504(c)
Comment: The paragraph allows for a mandatory life limit to be extended. M.A.503(c) states
that at the end of the approved limit the component should be removed.
Justification: Ensure consistency across the paragraphs.
Proposed Text: “(c) Components which have reached their certified mandatory life limit
limitation or contain a non-repairable defect shall be classified as unsalvageable and shall not
be permitted to re-enter the component supply system, unless the mandatory life limits
limitation has have been extended or a repair solution has been approved according to
M.A.304. “
response
p. 14

M.A.614 (b)
The BGA welcomes this clarification as it is sometimes difficult to obtain sailplane
maintenance record information from maintenance organisations.
response

NPA 2014-04, page 14/44, point M.A.614

NPA 2014-04, page 15/44, point 145.A.55
It is proposed to modify the paragraph (b) of the point M.A.614 and point 145.A.55 to read:
“M.A.614 Maintenance records
(b) The approved maintenance organisation shall provide the person or organisation
responsible for the aircraft continuing airworthiness with a copy of each certificate of
release to service to the aircraft owner, together and with a copy of any detailed
maintenance records associated with the work carried out and, when they are necessary to
demonstrate compliance with M.A.305.”
“145.A.55 Maintenance records
(b) The organisation shall provide the person or organisation responsible for the aircraft
continuing airworthiness with a copy of each certificate of release to service to the aircraft
operator, together and with a copy of any detailed maintenance record associated with the
work carried out and, when they are necessary to demonstrate compliance with M.A.305.”
It is now confirmed that in some cases, the person or organisation responsible for the
aircraft continuing airworthiness is no longer required to keep certificates of release to
service (ref. GM M.A.305(e)(3) for example). Further, it is also confirmed that some detailed
maintenance records associated with the work carried out are not needed by
owners/operators (ref. GM M.A.305, paragraph (6)). Therefore, the points M.A.614 and
145.A.55 should explicitly state that the person or organisation responsible for the aircraft
continuing airworthiness should be provided with certificates of release to service and
some/all associated records only when they are necessary to demonstrate compliance with
M.A.305.
response

NPA 2014-04, page 14/44, point M.A.614
NPA 2014-04, page 15/44, point 145.A.55
Could the Agency clarify the reasons why the retention period specified in the point
M.A.614(c) has not been aligned with the one of point 145.A.55(c)?
For sake of understanding.
response

M.A.604(c)
Shouldn’t M.A.604(c) also be changed to 3 years to be equivalent with the NPA 145.A.55(c)?
response

This comment applies both to M.A.614 (b) and to 145.A.55(b)
These two paragraphs ask for the maintenance organisation to provide the aircraft customer
(i.e. owner or operator) with a copy of certificate of release to service.
DGAC wonders what is the reason why the original would remain within the maintenance
organisation and not with the owner/operator ?
response

This comment applies both to M.A.614(b) and to 145.A.55(b).
These two paragraphs ask for the maintenance organisation to provide the aircraft customer
(i.e. owner or operator) with a copy of detailed maintenance records associated to
maintenance work, so the owner/operator stores compliance documentation according to
M.A.305.
DGAC wonders if there should be an AMC to describe what are the detailed maintenance
records that should be transmitted to owner/operator, possibly as originals, and the detailed
records that might stay as originals at maintenance organisation, without the need of a copy
to owner/operator.
When reading GM. M.A.305 (6), it states that “detailed maintenance records” kept by the
owner/operator are different from the “detailed maintenance records” required to be kept
by the maintenance organisation. Therefore, it seems there is a need for clarification about
the concept of “detailed maintenance records”.
DGAC considers the work done at CAMO level in the MA305 is very useful, and is kindly
asking EASA to perform similar work on M.A. 614(b) and 145.A.55(b).
response

M.A.614 (b), 2nd line
Add “/operator” after …”the aircraft owner”; it should read: …”the aircraft owner/
operator”…
response

Again, to what extend is the maintenance organisation required to provide copies and what
is the benefit of that (see M.A.305 (e) 3. (ii).)
response
p. 14

NPA 2014-04, page 14/44, point M.A.710
It is proposed to amend the item 7 of point M.A.710(a) to read:
“7. all service life limited life limited parts and time controlled components installed on the
aircraft are properly identified, registered recorded and have not exceeded their approved
service life mandatory airworthiness limitations limit; and”
Amendment of this point should be contemplated (holistic approach for consistency).
The term ‘registered’ may give the impression that components have registration marks like
aircraft. The term ‘recorded’ is preferred.
response

- M.A.710 (a) § 7. : there is still a reference to “service life limit” which is not in line with
the “new” wording used in this NPA. (cfr M.A.503).
response

Page No: 14
Paragraph No: M.A.710(a)7.

Comment: The term ‘service life’ has been removed from other paragraphs, this paragraph
should be consistent with those.
Justification: Inconsistency in terminology used.
Proposed Text: “7. all life limited parts and time controlled components installed on the
aircraft are properly identified, registered and have not exceeded their approved service life
limit; and”
response

M.A.710
 ”7. all service life limited life limited parts and time controlled components installed
on the aircraft are properly identified, registered and have not exceeded their approved
service life limit; and”
 Shouldn’t also the component with a certified life limit be mentioned to?
response

M.A.710 (a) 7. split and reworded as follow
7.
7. (i) life limited parts installed on the aircraft are properly identified, registered and have
not exceeded their service limits approved under the authority of the State of Design; and
(ii) all time controlled components installed on the aircraft are properly identified, registered
and have not exceeded their limits approved in the aircraft maintenance programme.
The term “service” is inconsistent, as mentioned in the point 2.3 “Summary of the Regulatory
Impact Assessment (RIA)”.
The term “approved” is confusing regarding the origin of the approval. The splitting in 2
points gives a clear overview of the different requirements during the airworthiness review.
This comment remains in line with the comments n°DACL-2014-04-01.
response
Similarly to the changes done in M.A.503 about the terms “service life”, DGAC recommends
deleting "service life" as follows at the end of § 7.:
"(…) have not exceeded their approved service life limit".
response

This should read ".... have not exeeded their approved service life limit, and" ??
response
p. 14
to Part-M) — Appendix II to M.A.201(h)1

2.11 : To be in coherency with other paragraphs, replace "scheduled maintenance" by "time
controlled"
response

NPA 2014-04, page 14/44, Appendix II to M.A.201(h)(1)
It is proposed to replace the title of paragraph 2.11 ‘Mandatory life limitation or schedule
maintenance controls & component control/removal forecast’ by ‘maintenance planning
activities’.
The contents of this paragraph are broader than the control of component maintenance.
They cover all maintenance planning activities (for the aircraft and components thereof).
response

NPA 2014-04, page 14/44, Appendix II to M.A.201(h)(1)
It is proposed to amend the paragraph 2.15 to read:

“2.15 Continuing airworthiness records
These may be maintained and kept by the sub-contracted organisation on behalf of the
operator who remains the owner of these documents. However, the operator should be
provided with the current status of AD compliance and service life limited life limited parts
and time controlled components data and statuses/reports required by point
M.A.305(b)1., M.A.305(c) and M.A.305(d), in accordance with agreed procedures. The
operator should also be provided with unrestricted and timely access to original any aircraft
continuing airworthiness records specified in point M.A.305 as and when needed. On-line
access to the appropriate information systems is acceptable.”
“The operator is ultimately responsible and therefore accountable for the airworthiness of its
aircraft. To exercise this responsibility the operator should be satisfied that the actions taken
by sub-contracted organisations meet the standards required by M.A. Subpart G” (AMC
M.A.201(h)(1)).
“[…] the operator is responsible for determining what maintenance is required, when it has
to be performed and by whom and to what standard, in order to ensure the continued
airworthiness of the aircraft being operated” (AMC M.A.201(h)). Continuing or continued
airworthiness?
To exert the responsibility described here above, the operator needs to access the life
accumulated by the aircraft, engine(s), propeller(s), and particular component(s), as
appropriate, and the statuses/reports specified in point M.A.305(c) and M.A.305(d), at least.
For example, the statuses listed in the proposed amendment will not completely help in
determining what maintenance for the airframe is required and when it has to be performed.
The continuing airworthiness of an aircraft cannot be established by considering AD and
components only.
The term ‘original records’ seems to be no longer pertinent as a result of the introduction of
the AMC M.A.305(e).
response

AMC M.A.201(h)(1)
It is proposed to amend the paragraph 6 to read:
“6. In order to retain ultimate responsibility the operator should limit sub-contracted tasks to
the activities specified below:
(a) airworthiness directive analysis and planning

(b) service bulletin analysis
(c) planning of maintenance
(d) reliability monitoring, engine health monitoring
(e) maintenance programme development and amendments
(f) aircraft continuing airworthiness records keeping
(fg) any other activities which do not limit the operators responsibilities as agreed by the
competent authority.”
For consistency with the Appendix II to M.A.201(h)(1) and the AMC M.A.305(f): the aircraft
continuing airworthiness records keeping activity should be listed as an activity an operator
may elect to sub-contract.
response
3. Proposed amendments — 3.1. Draft Opinion — 3.1.2. Annex II to Commission Regulation (EC)
p. 15
No 2042/2003 (Part-145) — Point 145.A.55

(b) : Do we need to consider "work carried out" as equivalent to "Dirty finger print" ?
If yes clarify § 3.2 GM MA.305 (6) concerning the notion of "dirty finger print may not need
to be transferred....."
response

M.A. 614(c) and 145.A.55(c) retention periods are not aligned. Please clarify
response

NPA 2014-04, page 14/44, point M.A.614
NPA 2014-04, page 15/44, point 145.A.55
It is proposed to modify the paragraph (b) of the point M.A.614 and point 145.A.55 to read:
“M.A.614 Maintenance records

(b) The approved maintenance organisation shall provide the person or organisation
responsible for the aircraft continuing airworthiness with a copy of each certificate of
release to service to the aircraft owner, together and with a copy of any detailed
maintenance records associated with the work carried out and, when they are necessary to
demonstrate compliance with M.A.305.”
“145.A.55 Maintenance records
(b) The organisation shall provide the person or organisation responsible for the aircraft
continuing airworthiness with a copy of each certificate of release to service to the aircraft
operator, together and with a copy of any detailed maintenance record associated with the
work carried out and, when they are necessary to demonstrate compliance with M.A.305.”
It is now confirmed that in some cases, the person or organisation responsible for the
aircraft continuing airworthiness is no longer required to keep certificates of release to
service (ref. GM M.A.305(e)(3) for example). Further, it is also confirmed that some detailed
maintenance records associated with the work carried out are not needed by
owners/operators (ref. GM M.A.305, paragraph (6)). Therefore, the points M.A.614 and
145.A.55 should explicitly state that the person or organisation responsible for the aircraft
continuing airworthiness should be provided with certificates of release to service and
some/all associated records only when they are necessary to demonstrate compliance with
M.A.305.
response

NPA 2014-04, page 14/44, point M.A.614
NPA 2014-04, page 15/44, point 145.A.55
Could the Agency clarify the reasons why the retention period specified in the point
M.A.614(c) has not been aligned with the one of point 145.A.55(c)?
response

Also here we advocate a retention period of three years related to the airworthiness review
cycle. See our comment to M.A.305.
response
comment 201 comment by: Aviteh Ltd.

There is no clear rule for maintenance organizations when they retain detailed maintenance
records on behalf of the owner/operator.
According to proposed 145.A.55(c) maintenance organization needs to retain a copy of
detailed maintenance records only for two years from the date the aircarft was released to
service.
M.A.305(e) requires that the owner/operator keep detailed maintenance records until such
time as the information is superseeded by new information equivalent in scope. This means
that in the case of records showing compliance with any AD, modifications and repairs, the
records must be kept as long as aircraft is in service or according to M.A.305(e)(4) 24 months
after the aircraft is permanently withdrawn from service.
Since GM M.A.305(6) gives the list of limited information that must be given by maintenance
organization to the owner/operator in the cases when they keep the records on behalf of
owner/operator it must be made clear that maintenance organization must fulfill the
requirements of M.A.305(e) which is not the case in propsed rule.
145.A.55(c) should be ammended to make it clear that there is exception to the
requirements of this paragraph when maintenance organization keeps records on behalf of
the owner/operator in which case the requirements of M.A.305(e) must be fulfilled by the
maintenance organization.
Right now if they follow 145.A.55(c) the records may be destroyed by the maintenance
organization after 2 years and owner/operator may not be able to show compliance with
M.A.305(e). This is already happening quite often in general aviation and creates a lot of
problems especially when the aircraft changes the owner.
response

145.A.55 ( c ): proposed requirement to keep a copy of all detailed maintenance records for
24 months.
Comment: This is inconsistent with the recently adopted approach to keep records in Part M
and Part 145 for 36 months in order to align with record retention period for the ARC
inspection.
response
145.A.55 ( c ): …”The organisation shall retain a copy of all detailed maintenance records and
any associated….”
Comment: it would be helpful if the guidance text on page 16 from GM M.A.305 (6) be
inserted in the 145.A.55 ( c ) requirement. And we mean part of the text in the sentence”
…Whereas maintenance organisations are required to retain all detailed records to
demonstrate that they worked in compliance with their respective requirements,…”
We would propose the text of 145.A.55 ( c ) to read: …”The organisation shall retain a copy
of all detailed maintenance records to demonstrate that they worked in compliance with
their respective requirements and any associated….”
This would assist Part 145 organisations in their regulatory reference for recordkeeping
procedures for detailed maintenance data such as lab records, welding details, oven settings
etc.
response

Similarly to the modification of 145.A.55 (c) change from three years to two years, DGAC
recommends EASA to do the same changes in M.A.614 (c) and M.A.614 (c) (3).
response

GM MA305, §2: LLP: there is no notion of the source which define the limitation (OEM), our
proposal is: "...whuch the maintenance schedule coming from the manufacturer of the ...".
For example we may have limitations coming from CMM.
§3 and in general in the document, there is a definition in the §1 which define what is
"applicable parameters", but, on the §3, why there is "any other applicable parameter (as
appropriate)". what does the term "appropriate" add? why we don't just have "...total
number of accumulated applicable parameters..."? or we may also replace in this paragraph,
"any other applicable parameter" by "any other additional parameter".
Anyway, some parameters seem to miss such as the Weight variant (for Airbus) or Variant
(for Boeing) and rating (for engines). It might be added in the definition of "applicable
paramater" in §1.
§4 What about removal for cleaning? ex: heat exchanger or ozone converter. Is cleaning and
lubrification as requested by some MRB tasks included? We have only the term replacement.
Does replacement include "close loop"?
What do you mean by "quantitative inspection"?
response

Then you reduce the storage time from 3 to 2 years. This will give a short timehorizon, if you
need to look back in history.
response
3. Proposed amendments — 3.2. Draft Decision — 3.2.1. Annex I to Decision 2003/19/RM (AMC
p. 15-17
to Part-M): — Point GM M.A.305

para (6) does not read correctly. Suggest "... the owner/operator should receive the aircraft
release to service performed during the maintenance and ALL DATA necessary to determine
the aircraft continuing airworthiness and its configuration, ..."
response

(6) Detailed maintenance records :
 Clarify the interaction in between § 145.A55 (d) and this paragraph concerning
"Detailed maintenance record" and "work carried out" ?
 Does it mean that "Dirty finger print" is not more considered to be kept as
subtantiating data to demonstrate compliance for an owner/operator ?
If yes, please clarify the retention period of "Dirty finger print" for owner/operator ?
 Add the definition of "Dirty finger print" ?
 2nd paragraph : add "data" before " necessary to determine the aircraft ......"
response

General comment:
While recognising that Part M embraces general aviation and commercial operations the
references to ‘owner’ and ‘operator’ could benefit from further clarification or a more
appropriate term may be considered (e.g. ‘person or organisation responsible for the aircraft
continuing airworthiness’).
GM M.A.305 paragraph 6.
‘Dirty Finger Print’ is a slang term and can be expected to become more obsolete as the use
of electronic signatures for maintenance activities becomes more prevalent. Please provide a
definition for the term or consider an alternate term (e.g. certified task card) that includes
‘dirty finger print’ as an example.

The distinction provided for the use of the term ‘detailed maintenance records’ as it applies
to maintenance organisations versus owners/operators, in which it is clarified that
maintenance organisations are required to retain more detail than owner/operators, is
helpful however the reference to ‘may not need’ in respect of ‘Dirty Finger Prints’ to be
retained by owner/operators is vague and appears subjective.
Additional clarification is needed such as ‘When a CRS for a major assembly details the work
performed on discrete elements of that assembly then individual ‘dirty finger prints’ do not
need to be transferred from the Part 145 organisation 5 to the owner/operator’.
The guidance should not suggest that the owner/operator can treat the Part 145 as an
extended library for future access to maintenance records and should instead be clear that
the owner/operator should obtain from the Part 145 organisation all maintenance records
necessary to demonstrate compliance with the owner/operators continuing airworthiness
management obligations from the Part 145 organisation.
response

NPA 2014-04, page 15/44, GM M.A.305
It is proposed to modify the paragraph (1) of the GM M.A.305 to read:
“(1) ‘Applicable airworthiness limitation parameter’ and ‘applicable parameter’ mean ‘in
flight hours’ and/or ‘in flight cycles’ and/or ‘in landings’ and/or ‘in calendar time’, and/or ‘in
any other applicable usage measurement unit’, as appropriate”.
This proposal has to be read in conjunction with point M.A.305(d)1. for example.
APU usage. The current definition does not take into account the possibility of measurement
units other than those listed.
response

NPA 2014-04, page 15/44, GM M.A.305

“(2) A ‘life limited part’ is a part for which the maintenance schedule of the aircraft
maintenance programme requires the permanent removal from service when, or before, the
specified mandatory life limitation in any of the applicable parameters is reached.”
A life limitation may be measured in more than one measurement unit, e.g. in flight hours
and in flight cycles. The basic rule should be conservative, i.e. to require the replacement of
life-limited parts at or prior to whichever of the mandatory life limitation in any applicable
parameters is reached first (unless otherwise specified in the relevant DAH instructions for
continued airworthiness or in the AD).
response

NPA 2014-04, page 15/44, GM M.A.305
“(4) The term ‘time controlled components’ embraces any component for which the
maintenance schedule of the aircraft maintenance programme requires periodically the
removal for restoration, the replacement, or the quantitative inspection of component’s
performance in a suitable approved workshop, after a service period controlled at
component level.”
Further, this paragraph refers to the term ‘restoration’ (GM M.A.305(d)(2) as well). Although
the use of this term in this context is found appropriate, could the Agency confirm the term
in the definition of ‘maintenance’ under which ‘restoration’ falls?
As currently written, the proposed definition could include components that are removed
periodically after a service period controlled at the airframe level: e.g. hydraulic or air filters.
The proposed definition includes the words ‘or the quantitative inspection of component’s
performance’. This suggests that all components subject to a functional check (i.e. a
quantitative check) would need to be declared as time controlled components. This includes
those that are checked on-aircraft (the majority) and thus extends the list of time controlled
components without proven necessity for an appropriate control of scheduled maintenance.
Therefore, it is assumed the time controlled components only relate to off-aircraft tasks.
Different definitions may be found in various locations of Regulations:
– The paragraph (h) of the Article 2 of the Regulation (EC) No 2042/2003 defines the term
‘maintenance’:
(h) ‘maintenance’ means any one or combination of overhaul, repair, inspection,
replacement, modification or defect rectification of an aircraft or component, with the
exception of pre-flight inspection.
– The Appendix II – Authorised Release Certificate EASA Form 1 defines the following terms:
(i) Overhauled. Means a process that ensures the item is in complete conformity with all the
applicable service tolerances specified in the type certificate holder’s, or equipment
manufacturer’s instructions for continued airworthiness, or in the data which is approved or
accepted by the Authority. The item will be at least disassembled, cleaned, inspected,
repaired as necessary, reassembled and tested in accordance with the above specified data.
(ii) Repaired. Rectification of defect(s) using an applicable standard (*).
(iii) Inspected/Tested. Examination, measurement, etc. in accordance with an applicable
standard (*) (e.g. visual inspection, functional testing, bench testing etc.).
(iv) Modified. Alteration of an item to conform to an applicable standard (*).
* Applicable standard means a manufacturing/design/maintenance/quality standard,
method, technique or practice approved by or acceptable to the Competent Authority.
– The point 21.A.431(c) in the Part-21 defines a repair:
(c) A ‘repair’ means elimination of damage and/or restoration to an airworthy condition
following initial release into service by the manufacturer of any product, part or appliance.
However, there is no reference to the term ‘restoration’.
response

NPA 2014-04, pages 15-16/44, GM M.A.305
The following paragraph refers to the term ‘action’:
“(5) […]. Any action that alters the periodicity of the maintenance task(s) or changes the
parameter of this periodicity should be recorded.”
Could the Agency confirm the term ‘action’ covers all cases?
It is proposed to amend the paragraph (5) of the GM M.A.305 to read:
“(5) […]. Any action approved data that alters the periodicity of the maintenance task(s) or
changes the parameter of this periodicity should be recorded.”
It is believed that an action is not systematically necessary to affect the periodicity of a
maintenance task. The term ‘approved data’ seems more appropriate (e.g. revision of a
periodicity for the inspection of an existing repair design).
response

NPA 2014-04, page 16/44, GM M.A.305
“(6) The term ‘Ddetailed maintenance records’ in point M.A.305 are refers to those records
produced by maintenance organisations that are required to be kept by the
owner/operator person or organisation responsible for the aircraft continuing
airworthiness. to be able They contribute to determine the aircraft continuing airworthiness
and the serviceability of both operational and emergency equipment, in particular for the
configuration of the aircraft in accordance with Part-M relevant for and the need for future
maintenance. These are different from only a part of the detailed maintenance records
required to be kept by a maintenance organisation as per M.A.614 or 145.A.55(c). Whereas
maintenance organisations are required to retain all detailed records to demonstrate that
they worked in compliance with their respective requirements, aircraft owner/operator the
person or organisation responsible for the aircraft continuing airworthiness needs to retain
those records required for assessing the aircraft configuration and the airworthiness of the
aircraft, engine(s), propeller(s) and all installed components installed subject to mandatory
instructions and associated airworthiness limitations. ‘Dirty finger prints’ may not need to
be transferred from the maintenance organisation to the aircraft owner/operator person or
organisation responsible for the aircraft continuing airworthiness. […]”.
It is proposed to simultaneously modify the AMC M.A.614(a) and GM 145.A.55(a) to read:
“AMC M.A.614(a) Maintenance records
1. Properly executed and retained aircraft continuing airworthiness records and
maintenance records provide owners, operators and maintenance personnel with
information essential in controlling unscheduled and scheduled maintenance, and trouble
The prime objective is to have secure and easily retrievable maintenance records with
comprehensive and legible contents. The aircraft maintenance records should contain basic
details of all serialised aircraft components and all other significant aircraft components
subject to mandatory instructions and associated airworthiness limitations installed that
are affected by the maintenance carried out, to ensure traceability to such installed aircraft
component documentation and associated M.A.304 M.A.401 maintenance data.”
GM 145.A.55(a) Maintenance records
“1. Properly executed and retained aircraft continuing airworthiness records and
maintenance records provide owners, operators and maintenance personnel with
information essential in controlling unscheduled and scheduled maintenance, and trouble
The prime objective is to have secure and easily retrievable maintenance records with
comprehensive and legible contents. The aircraft maintenance records should contain basic
details of all serialised aircraft components and all other significant aircraft components
subject to mandatory instructions and associated airworthiness limitations installed that
are affected by the maintenance carried out, to ensure traceability to such installed aircraft
component documentation and associated maintenance data as specified in 145.A.45.”
The Annex IV of Regulation (EC) No 216/2008 sets out the essential requirements for air
operations referred to in Article 8, and in particular with respect to continuing airworthiness
in the paragraph 6. It states that the aircraft must not be operated unless the operational
and emergency equipment necessary for the intended flight is serviceable. Point M.A.201
‘Responsibilities’ reminds that the person or organisation responsible for the continuing
airworthiness of an aircraft shall ensure that no flight takes place unless any operational and
emergency equipment fitted is correctly installed and serviceable or clearly identified as
unserviceable. In order to ensure consistency, a wording about operational and emergency
equipment is added to the paragraph (6) of the GM M.A.305 and is based on the
introductory sentence of point M.A.301, which defines the continuing airworthiness tasks.
This new GM confirms that in some cases, the person or organisation responsible for the
aircraft continuing airworthiness is no longer required to keep some detailed maintenance
records associated with the maintenance work carried out. The term ‘all components
installed’ is not precise enough. The person or organisation responsible for the aircraft
continuing airworthiness should be provided with records only when they are necessary to
demonstrate compliance with M.A.305. Wording about components has been amended for
consistency with paragraph (e) of the AMC M.A.305(c)2.
Then, the amendment of the AMC M.A.614(a) and the GM 145.A.55(a) is proposed to ensure
consistency with the paragraph (6) of the GM M.A.305 introduced by the NPA 2014-04. The
use of the term ‘aircraft record’ in the first paragraph of the AMC M.A.614(a) and the GM
145.A.55(a) is confusing:
Is reference made to aircraft continuing airworthiness records, maintenance records, or
both?
The notion of ‘other significant aircraft components’ is ambiguous. Some competencies
pertaining to the design domain are required to establish the list of such ‘other significant
aircraft components’: should the design approval holders be not involved, some components
could be missed, or conversely, the list could create an unnecessary burden on maintenance
organisations. Therefore, a provision referring to ‘other components subject to mandatory
instructions and associated airworthiness limitations’ has been added for consistency with
the paragraph (6) of the GM M.A.305.
response

NPA 2014-04, page 16/44, GM M.A.305
“[…]
Where the maintenance organisation retains the detailed maintenance records in
accordance with 145.A.55(c) and or M.A.614(c), the owner/operator person or organisation
responsible for the aircraft continuing airworthiness should receive the aircraft and/or
component certificate(s) of release to service performed during issued at the completion of
the maintenance and together with the associated detailed maintenance records, when
these certificates and detailed maintenance records are necessary to determine the aircraft
continuing airworthiness and the serviceability of both operational and emergency
equipment, in particular for it’s the aircraft configuration, and the need for future
maintenance. The aircraft certificate of release to service should which includes directly or
indirectly references to all: […]”.
The aircraft certificate of release to service is issued at the completion of (not during) any
maintenance (point 145.A.50(b)).
The person or organisation responsible for the aircraft continuing airworthiness should
receive data/documents only when these data/documents are necessary to determine the
aircraft continuing airworthiness and the serviceability of both operational and emergency
equipment. Further, component maintenance needs to be taken into account to achieve this
objective.
The instructions to complete an EASA Form 1 specify that the block 12 describes the work
[…], either directly or by reference to supporting documentation, necessary to determine the
airworthiness of item(s) in relation to the work being certified. Therefore, the reference to
data/documents necessary to determine the aircraft continuing airworthiness and/or the

serviceability of both operational and emergency equipment may be included in the
supporting documentation related to the EASA Form 1.
response

NPA 2014-04, page 16/44, GM M.A.305
The paragraph (8) of the GM M.A.305 states “Some abnormal conditions that could be kept
under this requirement could be lightning strikes, hard landings, long term storage, propeller
or rotor over-speed, over-torque, impact on a main rotor blade, etc.”
Could the Agency clarify the reasons why ‘long term storage’ is considered as an abnormal
condition?
“(8) ‘Other maintenance required for continuing airworthiness’ means other unscheduled
maintenance due to abnormal or particular conditions or events with an impact on the
continuing airworthiness of the aircraft at the time of its return to service. It is not intended
to request every single condition described in the maintenance data, i.e. e.g. Aircraft
Maintenance Manual chapter 5, but just the ones that cannot be captured by other means,
for example when those are not included in the records for repairs. Some abnormal or
particular conditions or events that could be kept under this requirement could be lightning
strikes, hard landings, long term storage, propeller or rotor over-speed, over-torque, impact
on a main rotor blade, etc.
Such maintenance may include component maintenance performed in a suitable workshop
to appropriately address the abnormal or particular condition or event, e.g. to confirm the
serviceability of operational and/or emergency equipment.”
The term ‘other maintenance required for continuing airworthiness’ is used in the point
M.A.305(e)2.(iii) to contrast with the term ‘scheduled maintenance’. Therefore, can ‘other
maintenance required for continuing airworthiness’ be anything but unscheduled
maintenance? If it can, some explanations are requested.
The term ‘abnormal or particular conditions or events’ is proposed so that long term storage
is not considered as an abnormal condition or event, like dust storms or tail runway impacts
can be.
response

NPA 2014-04, pages 16-17/44, GM M.A.305
The paragraph (9) of the GM M.A.305 states:
“Such records [in-service history records] document each time a life limited part is placed in
service or removed from service. They should clearly: […]
(iv) show the total in-service life accumulated in flight hours and/or flight cycles and/or
landings and/or calendar time and/or any other applicable parameter, as appropriate,
corresponding to the dates of installation and removal of the part.”
Could the Agency clarify which total in-service life accumulated is to be shown?
Is it the total in-service life accumulated by:
– the part,
– the next higher product or particular component (i.e. the APU for example or the propeller,
the engine, or the aircraft) the part is fitted to,
– both the part and the next higher product or particular component, or
– something else?
“Such records document each time a life limited part is placed in service or removed from
service. They should clearly: […]
(iv) Show the total in-service life accumulated in flight hours and/or flight cycles and/or
landings and/or calendar time and/or any other applicable parameter, as appropriate,
corresponding to the dates of installation and removal of the part.
The life accrued by the life limited part between any installation and a consecutive removal
should be consistent with the life accumulated by the relevant product/particular
component (e.g. the Auxiliary Power Unit) that is recorded in accordance with point
M.A.305(b)1. for the same period.”

Compliance with mandatory life limitations is crucial to the aircraft continuing airworthiness
as established by point M.A.305. The quality of the mandatory life limitations control is
dependent on the three elements involved in calculations:
– the selection (and adjustment, if necessary) of the relevant life limitations, which depend
on the configuration of the product/particular component,
– the accuracy of calculations of the life limited part’s accumulated life, and
– the accuracy of the calculation of the life limited part’s remaining life.
Extensive experience on large aeroplane life limited parts shows that a significant source of
errors in the control of mandatory life limitations is the lack of checks of the part’s life
accumulation. To correct this gap, it is necessary to request a confirmation that the life
accrued by the life limited part, between an installation and a consecutive removal, is
consistent with the life accumulated by the relevant product/particular component for the
same period.
response

- GM M.A.305 § (5) : the word “in” should be added in : “…by the affected components
in the applicable parameter, as appropriate…”.
response

- GM M.A.305 § (6) : it is important to refer also to the necessity to ensure the traceability of
the work performed to be able to demonstrate that the aircraft is in line with the M.A.902
requirements. We can propose this kind of additional wording : “ ‘Detailed maintenance
records’ are those records required to be kept by the owner/operator to be able to
determine the continuing airworthiness and configuration of the aircraft in accordance with
Part-M relevant for future maintenance and/or to ensure the traceability of the work
performed on aircraft to demonstrate compliance with M.A.902”. - GM M.A.305 § (6) :
concerning the content of this paragraph after the first sentence, we have some matter of
concern. The operator/owner needs to have the detailed records of the works performed on
aircraft to ensure their responsibilities in term of M.A.201 and to be in compliance with the
M.A.902. In these circumstances, if the operator/owner does not receive the record like
work cards (“dirty finger prints”) but only a document (like a tally sheet) that refers only to a
work card number or an AD number or a repair description, the operator/owner cannot
ensure adequately their responsibilities described in the M.A.201 and M.A.708 (for PART-M
Subpart G) for example. However, with this GM paragraph, in our understanding, it seems
that a simple cross-reference is sufficient for EASA.
We think this approach is not a good way :

a) to ensure an adequate level of safety with sufficient proof. Indeed, it is important tohave
sufficient “safety nets” to avoid as much as possible any safety issue. Moreover, in case of
serious incident or accident, without access to sufficient records (like dirty finger prints that
contain all the details of works performed), an adequate investigations and adequate
corrective/preventive actions necessary to improve the safety in aviation will not be possible.
We can give you the following example that is based on a loss of an aircraft several years ago
: a crash occurred 12 years after a reparation was performed on the aircraft. The repair was
not performed adequately and it was discovered with the dirty finger prints and the
wreckage. With the proposal of the NPA, it will not be possible to do the investigation
correctly due to the fact that important information will not be available. This example can
be enlarged to other incidents also.
b) to give sufficient information to the operator/owner to ensure the continuing
airworthiness of the aircraft. Indeed, if the operator/owner does not have access to the dirty
finger prints (work cards), he does not have the necessary information to perform the
adequate review to up-date his “information technology system”. For example, without dirty
fingers prints, when applicable, how the operator/owner can verify : *the corrosion findings
on its aircraft ; *the result of certain inspections that have an impact for the future follow-up
(ex : AD that have different requirements depending of the result of the inspection,…);
*the reliability study and the development of the maintenance program based on the
findings during maintenance checks ;
*the requirements for repairs/damage follow-up ;
….
This comment could have also an impact on the “AMC M.A.305 (f)” as it is written in the
NPA.
response
GM M.A. 305 (6)
1. The terms owner/operator are often used together and intermingled, a clear
separation should be stated as to their responsibility regarding commercial aviation. If the
term "owner" is only required to cover general aviation, a more precise terminology would
be good in order to avoid confusion with aircraft lessors/financers. This applies not only to
this paragraph.
2. The sentence "Dirty finger prints may not be needed..." is not very precise and may
lead to problems when aircraft are transferred between different operators who have
different understandings of what may or not may be needed. The regulation should clearly
state that an operators needs all detailed maintenance records to demonstrate
airworthiness. This also includes maintenance compliance proof such as stamped jobcards
(e.g. where jobcards record certain measurements/dimensions/findings). The term "dirty

finger prints" should include any other future equivalent of "dirty finger prints", I encourage
the use of a more precise term and use DFP as one example (e.g. "Proof of maintenance
performance, e.g. stamped jobcards 'dirty finger prints').
response

Dirty finger prints:
Did any one from you an aircraft maintenance? Any worker uses a checklist to do his job.
And, of course, it is normal that a dirty finger print will land on the paper.
Sorry, but this proposal is a big bullshit. Delete it, quick!
(Or, may I can use such derictive to fire the damned maintenance stuff, when he puts a dirty
finger print on the papers?)
response
comment 211 comment by: DLH and LHT

GM M.A.305 (2): "[...] maintenance schedule of the aircraft maintenance programme [...] "
should be changed into "[...] airworthiness limitation section [...]". Else, e.g. oxygen bottles,
cartriges or filters, having a maintenance task "discard" would be treated the same.
response

GM M.A.305 (9) (iii): Please note comment No. 214 (with regard to App III to GM1
M.B.303(b) 'Key Risk Elements' C.2 Component control Typical inspection items 4.)
response

Comment 1
GM M.A.305 Aircraft continuing airworthiness record system
(1) This definition is too restrictive. For example, certain engine components may have
maintenance tasks and/or lives expressed in terms of "engine cycles" which do not
necessarily correlate to "flight cycles". The record system must be able to indicate/control
the maintenance tasks and/or lives of such components in relation to the parameter defined
in the design approval holder's source document, e.g. the MRB report or Engine Manual
Chapter 5.
We recommend the following definition:

(1) Applicable airworthiness limitation parameter’ and ‘applicable parameter’ mean ‘in flight
hours’ and/or ‘flight cycles’ and/or ‘landings’ and/or ‘calendar time’, and/or other
parameter, as defined in the aircraft maintenance programme, e.g. engine cycles, as
appropriate.
Comment 2
(6) We believe the differentiation between "detailed maintenance records" in respect to
M.A.305 and the differing interpretation in respect of 145.55(c) is unnecessary and will cause
confusion. It also appears to place an additional burden on the maintenance organisation to
extract information and provide this to the owner/CAMO, instead of simply transferring the
"dirty finger prints" (or electronic copies thereof) as is current practice.
If EASA continues to consider the need for this difference, then:
 a new term should be used in M.A.305, e.g. "detailed maintenance information", and
 rule material should describe who is reponsible for extracting this "information"
from the (dirty finger print) "records", and
 how this should be done.
Comment 3 (refer also to comment 217)
There does not appear to be a requirement to keep CRS and detailed maintenance records in
relation to defect identification and/or investigation and/or rectification. "other
maintenance required for continuing airworthiness" could include this, but the definition in
the GM only relates to "abnormal" or "occurrence-based" defects. We feel this is a significant
omission and must be included as follows:
M.A.305 Aircraft Continuing Airworthiness Record System
(e)
...
2 General data:
...
(iii) the certificate of release to service and detailed maintenance records of all scheduled
maintenance, defect investigation and rectification, or other maintenance required for
continuing airworthiness in respect of the aircraft, engine(s), propeller(s), as appropriate;
response

Para 9: The term "in-service history records" has been introduced and is defined as "such
records document each time a life limited part is placed in service or removed from service".
In the Regulatory Impact Assessment Para 4.3.3 and Analysis of Impacts Para 4.4.3, "In
service history" records are referred to in both areas as the keeping of "some records", "not
keeping this history from the birth of the component, but from a certain time" and "only
some records are requested". The statements in 4.3.3 and 4.4.3 do not seem to cover the
definition from GM M.A. 305 Para. 9 and as such it would appear that the impact of this
definition for life limited parts has not been completely addressed.
Also, one of the issues that is intended to be addressed by this NPA is the lack of
harmonisation with FAA requirements in relation to continuing airworthiness records, but in
Para. 4.3.8 and 4.4.8, this has been listed as already covered by the Bilateral Agreement - this
issue would not appear to be clearly addressed in the existing Bilateral Agreement as the
requirements for the retention of records for life limited parts differs significantly from the
FAA requirements in this regard (Ref. FAA AC 120-16F Chapter 8-12) which leads to issues
during the transfer of parts between these jurisdictions.
response

GM M.A. 305 (3):” The ‘current status of life limited parts’ should indicate, for each affected
part,……”.
Comment: in the case of engines, the same part could be installed in different engine models
with , most likely, also different thrust ratings . So a wider interpretation is necessary.
response

GM M.A. 305 (4): …..” The term ‘time controlled components’ embraces any component for
which
the maintenance schedule of the aircraft maintenance programme requires
periodically the removal for restoration, the replacement, or the quantitative
inspection of component’s performance…...
Comment: Aircraft maintenance programmes for the same type of aircraft worldwide may
differ. Therefore (because of pooling and leasing contracts) it is safer to refer to OEM
MRB/MPD. So the text should read:
…..” The term ‘time controlled components’ embraces any component for which
the maintenance schedule of the OEM MRB/MPD requires
inspection of component’s performance…...
response

GM M.A. 305 (5)
Comment:
The text proposes that the current status of time controlled components should include the
life accumulated by the affected components. As proposed, these components could include
non-serialized parts, such as filters, batteries, cartridges of fire extinguishers, etc.
Maintenance actions to such parts are typically managed with aircraft level instructions in
the aircraft maintenance program, and not at component level. Requiring component level
tracking of such parts would result in a significant burden to the operators.
Suggested resolution:
Restrict the requirement to include the life accumulated by the affected components in the
current status of time controlled components only to components that were serialized by the
Design Approval Holder (DAH).
response

GM M.A. 305 (5) : “…….since the last accomplishment of scheduled maintenance specified in
the maintenance schedule of the aircraft maintenance programme”.
Comment: change text to add “engine”:
“…….since the last accomplishment of scheduled maintenance specified in the maintenance
schedule of the aircraft / engine maintenance programme”.
response

GM M.A.305 (6): …. which includes references to all:
— taskcards,
— modifications,
— airworthiness directives,
— repaired and non-repaired damage, and
— measurements relating to defects.
Comment: This last bullet , “measurements relating to defects” would be an undue burden
on Maintenance Organisations’ record keeping activities. Please explain what is meant here.
response

GM M.A.305 (9) (iv): “Any other events that would affect the life limitation, such as a
modification
(in accordance with airworthiness directives, service bulletins or any
product improvements) that affects the life limitation or changes the
limitation parameter, must also be included in the in-service history record.
Not all modifications would necessarily be pertinent to the life limitation of
the component”.
Comment: identical components can be installed on different engines. The situation that
some repairs (on such components) may be allowed on one engine type but not on another
engine type should also be covered here. “Departures” (one-time approval of deviations) can
also be engine type specific.
response

GM M.A.305 (2): "[...] maintenance schedule of the aircraft maintenance programme [...] "
should be changed into "[...] airworthiness limitation section [...]". Else, e.g. oxygen bottles,
cartridges or filters, having a maintenance task "discard" would be treated the same.
response

GM M.A.305 (9) (iii): Please note comment No. 214 (with regard to App III to GM1
M.B.303(b) 'Key Risk Elements' C.2 Component control Typical inspection items 4.)
response
comment 260 comment by: CAI FIRST

(4) The term ‘time controlled components’ embraces any component for which
the maintenance schedule of the aircraft maintenance programme requires
inspection of component’s performance (for ELT batteries ref. to AMC 1 CAT.IDE.A.280,
AMC1 NCC.IDE.A.215, AMC1 NCO.IDE.A.170).
(6) ‘Detailed maintenance records’ are those records required to be kept by the
owner/operator to be able to determine the continuing airworthiness and configuration of
the aircraft in accordance with Part-M relevant for future maintenance. These are different
from the detailed maintenance records required to be kept by a maintenance organisation as
per M.A.614 or 145.A.55(c). Whereas maintenance organisations are required to retain all
detailed records to demonstrate that they worked in compliance with their respective
requirements, aircraft owners/operators need to retain those records required for assessing
the aircraft configuration and the airworthiness of the aircraft and all components installed.
‘Dirty finger prints’ may not need to be transferred from the maintenance organisation to
the aircraft owner/operator but often dirty finger are necessary to assess the aircraft
configuration and must be retained (i.e. if an operator engineering order or TCH
maintenance data address a multiple choice of task)
JUSTIFICATION:
-provision to following tasks may be added
AMC1 CAT.IDE.A.280 Emergency locator transmitter (ELT)
BATTERIES
(a) All batteries used in ELTs should be replaced (or recharged if the battery is rechargeable)
when the equipment has been in use for more than 1 cumulative hour or in the following
cases:
(1) Batteries specifically designed for use in ELTs and having an airworthiness release
certificate (EASA Form 1 or equivalent) should be replaced (or recharged if the battery is
rechargeable) before the end of their useful life in accordance with the maintenance
instructions applicable to the ELT.
(2) Standard batteries manufactured in accordance with an industry standard and not having
an airworthiness release certificate (EASA Form 1 or equivalent), when used in ELTs should
be replaced (or recharged if the battery is rechargeable) when 50 % of their useful life (or for
rechargeable, 50 % of their useful life of charge), as established by the battery manufacturer,
has expired.
(3) The battery useful life (or useful life of charge) criteria in (1) and (2) do not apply to
batteries (such as water-activated batteries) that are essentially unaffected during probable
storage intervals.
(b) The new expiry date for a replaced (or recharged) battery should be legibly marked on
the outside of the equipment.
AMC1 NCC.IDE.A.215 Emergency locator transmitter (ELT),
AMC1 NCO.IDE.A.170 Emergency locator transmitter (ELT)
-dirty finger often is the mean to assess which task or maintenance data was applied
response

This comment has been attached to GM M.A.305 (1) but if retained it would lead to changes
in several over paragraphs.
The term “applicable parameter” when used for instance in M.A.305 (b)(1) only covers
“calendar times” which is not directly written in that paragraph.
It is recommended to avoid the use of the term in conjunction with a list of its items:
“Flight cycles (FC) and/or flight hours(FH) and/or applicable parameters” should either be
“applicable parameters” or “FC and/or FH and/or landings and/or calendar times”.
DGAC prefers that last way to write items as it is directly explicit.
Regarding the “applicable airworthiness limitation parameter”, it is only used once in
M.A.305(d)(1). It is recommended to remove from the GM that definition, and directly put
appropriate words in the corresponding referenced paragraph.
Example of change:
M.A.305(d)1) : current status of life limited parts including the life accumulated by each
affected part in relation to the applicable airworthiness limitation parameter appropriate
limitation expressed in flight cycles or flight hours or landings or calendar times ; and
response

GM M.A.305 (2) AND (4) REWORDED AS FOLLOW
(2) A ‘LIFE LIMITED PART’ IS A PART FOR WHICH THE MAINTENANCE SCHEDULE OF THE
AIRCRAFT MAINTENANCE PROGRAMME REQUIRES THE PERMANENT REMOVAL FROM
SERVICE WHEN, OR BEFORE, THE SPECIFIED MANDATORY LIFE LIMITATION APPROVED
UNDER THE AUTHORITY OF THE STATE OF DESIGN, IN APPLICABLE PARAMETER, IS
REACHED. (4)THE TERM ‘TIME CONTROLLED COMPONENTS’ EMBRACES ALL THE
COMPONENTS OTHER THAN LIFE LIMITED PARTS FOR WHICH THE MAINTENANCE SCHEDULE
OF THE AIRCRAFT MAINTENANCE PROGRAMME REQUIRES PERIODICALLY THE REMOVAL FOR
RESTORATION, THE REPLACEMENT, OR THE QUANTITATIVE INSPECTION OF COMPONENT’S
PERFORMANCE
REASON / JUSTIFICATION:
THE DEFINITIONS, AS DESCRIBED IN THE PROPOSED GM M.A.305, ARE CONFUSING: THE
‘TIME CONTROLLED COMPONENTS’ SEEMS TO ENCOMPASS THE DEFINITION OF ‘LIFE
LIMITED PARTS’. NEVERTHELESS, BOTH DEFINITIONS APPEAR AT THE SAME TIME IN OTHER
PROPOSALS AS SEGREGATE CONCEPTS (E.G. TITLE OF SECTION M.A.503 OR IN M.A.710 (A) 7).
AS SUCH, THEY SHOULD BE CLEARLY DISTINGUISHED BY DEFINING THEIR CONTENT AND
ORIGIN.
response

Rewrite GM M.A.305 (6) to avoid the loss of airworthiness records by using only the
reference on the CRS. In particular, the “references to all” in the following sentence should
be suppressed:
“(…) the owner/operator should receive the aircraft release to service performed during the
maintenance and necessary to determine the aircraft continuing airworthiness and its
configuration, which includes references to all: (…)”
REASON/JUSTIFICATION:
As written, one can understand that demonstration of the continuing airworthiness of the
aircraft is limited to the use of references from the previous maintenance package to plan
the “relevant future maintenance”.
The definition of detailed maintenance records for the Part M organisation should
encompass in addition to the proposed definition all the elements necessary to
demonstrate the continuing airworthiness of the aircraft. As an example, the detailed
maintenance records of the Part 145 include several additional information useful to track
the airworthiness (Ex: the dimensional information required by AMC M.A.801(f) and AMC
145.A.50(b)). However, those information are not contained in the “references”.
After the 2 years period, this additional information retained by the Part 145 could be lost.
While it can be easily understood that all work cards and “dirty finger prints” do not need to
be transferred to the owner/operator, it is however important to include all the information
pertinent to the continuing airworthiness (specific methods / measurements / level of
deterioration / etc.) but not covered by the actual proposed definition of “detailed
maintenance record” for the Part M.
response

M.A.305 and associated AMC /GM precise what is expected for each aircraft covered by the
Basic Rule EC 216/2008 in term of continuing airworthiness records. It should be important
to sensibilize the actors (owners, operators, CAMOs) there are in certain cases others
additional rules in this domain which could be defined by the owners by contract with
operators/CAMO due to the potential consequences on the values of the aircraft, a simple
nota on this domain could be very useful.
Add the following note at the end of GM M.A.305 :
“Note : M.A.305 and associated AMC /GM precise what the aircraft continuing airworthiness
records are. It does not prevent the Operators/CAMO to keep additional records as per their
commercial/financial contract with aircraft owners/operators”.
response

Attachments #2 #3 #4 #5 #6 #7
Page 16, §6 3rd phrase. It is not clear. Does it mean that owner/operator keep exactly the
same things as the maintenance organisation? or just the release and list (reference) of tasks
performed?
We see a risk of safety (mainly during redeliveries to owner by operator) from our
understanding. From our experiments, there are lots of mistakes on the status, so, if we just
keep the status, we may miss many things. DFP is the only way to cross check the statuses as
of today. (See OCR attached provided to DGAC).
To be clear, the term "detailed maintenance records" seems to not be convenient in the Part
M as we are only working on statuses? the details are in the MRO (if he keeps the detailed
data).
response

(iv) why is there "any other applicable parameter"? mismatch with the definition. From our
point of view, it is not in accordance with "detailed maintenance records". to determine the
MTS (movement traceability sheet), we need the DFPs.
response

GM M.A.305 item (9) - IATA has worked with industry stakeholders on a draft template to
define such contents and can share the contents of the template to be used as the industry
“standard”.
response

General comment: We propose that there is an effective data for the new record
management. The new information on “in-service history records” should apply after an
effective day; therefore, an operator should not have to go back to create such historical
records if it had a different approved system prior to the effective date.
response

General Comment: It needs to be a clear differentiation between the in-service history
records for Engine, APU, Landing Gear LLPs and parts such as O2 generators, squibs etc. Items
that have an expiration date only (O2 generators, etc.) should be treated differently than
parts having a cycle/flight hour limitation (engine disks etc.).
response

page 16/44
(6) "Detailed mainenance records"
What is the meaning of "dirty finger prints"?
Proposal:
Please replace this term.
Rationale:
This is colloquial English, most probably not understood by many within the community.
response
comment 330 comment by: SAS Technical Operations

SAS suggest EASA to clarify that there is no need for an”in-service history” for Life Limited
Parts which does not have an operational history dependent limitation e.g. different limits
for different applications, weight variants, thrust ratings etc.
If there is an operational history dependent limitation on the Life Limited Part an”in-service
history” is needed in order to recalculate the usage and calculate the new limit. But for the
standard LLP this is not the case.
response

For us it does not make any sense to have a definition of "life limited parts" and "time
controlled component" to be based on the content of the maintenance program [point (2)
and (4)].
The definition should be based on requirements issued by the Type Certificate Holder of the
aircraft or the component.
The term "current status" is not defined at all. Does "current" mean "after each flight" as
stipulated in M.A.305 (b), or once per day, once per year??

Under (6): is "measurements relating to defects" correct? (measures relating to defects?)
response

GM M.A.305 (6) states that the owner/operator needs to ‘retain those records required for
assessing the aircraft configuration and the airworthiness of the aircraft and all components
installed’. Please clarify ‘all components’ as used in this sentence as it would imply that the
record detail and records retention requirements are no different for CM Components than
Time Controlled Components or LLPs?
response
p. 17
to Part-M): — Point AMC M.A.305(b)1

NPA 2014-04, page 17/44, AMC M.A.305(b)1
It is proposed to amend the AMC M.A.305(b)1 to read:
“(a) Some gas turbine engines are assembled from modules and the total life accumulated in
service for the complete engine may not be kept. When owners and operators wish to take
advantage of the modular design, then the total life accumulated in service for each module,
and maintenance records for each module, should be maintained. The continuing
airworthiness records as specified should be kept with the module and should show
compliance with any mandatory requirements pertaining to that module.
(b) The accomplishment of some scheduled maintenance tasks may be controlled by usage
measurement units asynchronous to those used for recording the in-service life
accumulation of the aircraft, engine(s) and/or propeller(s). The recording of in-service life
accumulation may be necessary also in other measurement units to ensure the continuing
airworthiness of the aircraft. For example, a mandatory life limitation measured in cycles
of Auxiliary Power Unit usage may apply to some rotating parts. In such a case, APU cycles
need to be recorded.
It is not intended to request the recording of in-service life accumulation in measurement
units of usage for every single component. It is limited to the particular components
involved by at least one mandatory maintenance task from the maintenance schedule of
the aircraft maintenance programme that is controlled by such asynchronous usage
measurement units.”
APU usage. The requirement does not take into account the possible need for recording lives
asynchronous to those of products.
See also the comment on M.A.305(b)1.
response

We suggest to create a new AMC M.A.305(a) & (d)
Proposal:
‘ The inclusion of the certificate of release to service in the aircraft continuing airworthiness
records means that the date and/or flight parameter at which the maintenance was
performed, including a unique reference to the CRS document should be processed in the
record system in order to establish the next maintenance due and to establish traceability to
the maintenance (repair/modification) performed.
For components, this information should be included on the in-service history card unless
the applicable authorized release form (EASA Form 1 or equivalent) contains all relevant
information required by M.A.305.
For a component (i.e., an assembly) that contains several sub component which are subject
to airworthiness limitations (e.g., landing gears and APU’s), the part- and serialnumber and
other relevant information of the installed subcomponents should be included in the
assembly in-service history record. ’
Explanation:
There is no AMC to the rule. To provide clarification and AMC.
response

Some gas turbine engines are assembled from modules and the total life accumulated in
service for the complete engine may not be kept. When owners and operators wish to take
advantage of the modular design, then the total life accumulated in service for each module,
as well as in-service hystory if applicable, and maintenance records for each module, should
be maintained. The continuing airworthiness records as specified should be kept with the
module and should show compliance with any mandatory requirements pertaining to that
module
JUSTIFICATION: In line with GM MA 305 (9) and reason of mantaining Total Life
response

AMC M.A.305(b)1 Aircraft continuing airworthiness record system
We support the need for this explanation on the modularity of engines, but also believe it
should refer to modular propellers, as follows:
"Some gas turbine engines and some propellers are assembled from modules and the total
life accumulated in service for the complete engine or propeller may not be kept. ... ."
response
p. 17
to Part-M): — Point AMC M.A.305(c)1
comment 14 comment by: Nayak Aircraft Services

Die Lesart kann so interpretiert werden ,das hier auf die Flugzeugmuster und nicht auf
Flugzeugbaureihen Bezug genommen wird..
Das bedeutet bei einer Cessna 172N, dass die komplette Cessna 172 Serie (A bis S)
abgebildet werden müsste, und z.B. alle möglichen Propellertypen und Motormuster
abgedecken zu können. In den AD-Listen werden dann alle Motoren von Continental über
Lycoming bis Thielert aufgezeichnet werden.
Die Folge ist, dass Seitenlange und unüberschaubare A/D-Listen entstehen werden. Die
Sicherheit des Flugzeuges wird dadurch keinesfalls erhöht, im Gegenteil sie wird
verschlechtert, da die Übersichtlichkeit fehlt, und wesentliche Punkte vergessen werden
können.
Zur Zeit haben diese Flugzeuge im Schnitt schon 15 bis 20 Seiten AD-Übersichts-Listen.
Dieses würde nach der geplanten Umsetzung auf das 5 bis 10 Fache ansteigen.
Eine eindeutige definition ist erforderlich, damit die Papierflut in engen Grenzen gehalten
wird.
Axel Neitzert
techn. Referent BBAL
response

AMC MA.305 (c) 1 (a) :
 Notify if a current AD status needs to indicate all link withg former "Superseded AD"?
 2nd paragraph : Replace "Why it is not applicable" by "why it is not concerned"
 3rd paragraph : Replace "for repetitive ADs or measures, only the date of the last...."
by "for repetitive ADs or measures, only the applicable parameters of the last
 Add clarification about recording date : do we have to record "execution" or "release
to service" date ?
response

NPA 2014-04, page 17/44, AMC M.A.305(c)1
It is proposed to amend the AMC M.A.305(c)1 to read:
“(a) The current status of ADs, and measures mandated by the competent authority in
immediate reaction to a safety problem, should identify the product/component, the
applicable ADs applicable to the product and components thereof, including revision or
amendment numbers and the date on which the status was updated. It should not list those
superseded or cancelled.
If the AD is generally applicable to the aircraft product or component type but is not
applicable to the particular aircraft, engine, propeller or component, then this should be
identified with the reason why it is not applicable.
The AD status should include the release to service date on which the AD or measure was
accomplished (the date the certificate of release to service was issued), and where the AD
or measure is controlled by flight hours and/or flight cycles and/or landings and/or any other
applicable parameter, as appropriate, it should include the corresponding total life
accumulated in service on the date when the AD or measure was accomplished. For
repetitive ADs or measures, only the dates of the last and next applications should be
recorded in the current status. The status should also specify the method of compliance and
which part of a multi-part AD or measure has been accomplished, where a choice is available
in the AD or measure.
When the AD is multi-part or requests assessments of certain inspections, this information
should be shown as well.
The current status of AD should reference the certificate(s) of release to service showing
the demonstration of compliance.”
Editorial: there is no need for bullet (a) because there is no bullet (b).
The term ‘applicable’ used alone may be the source of different interpretations (ADs
applicable to a product vs. ADs that apply because they are not cancelled or superseded).
The wording ‘ADs applicable to the product and components thereof’ helps in addressing
different situations (for example, an engine managed separately. Refer to AMC M.A.305(b)1).
The term ‘product’ is defined in the Regulation (EC) 216/2008.
Experience shows it is necessary to clarify the Agency’s position on the need (or absence
thereof) for listing the ADs and measures that have been superseded or cancelled. This will
prevent endless discussions, for example at the time of aircraft transfer. It is proposed to not
list them: traceability is ensured at the Agency or competent authority level.
The wording ‘the date the certificate of release to service was issued’ is preferred to the
term ‘release to service date’. The term ‘certificate of release to service’ is widely used in the
Part-M and Part-145.
For repetitive AD, the date of the last and next applications is not necessarily enough: record
of flight hours and/or flight cycles and/or landings and/or any other applicable parameter
may be needed. To keep consistency with the preceding sentence, reference to the ‘date’
has been deleted.
A link between the continuing airworthiness management domain and the maintenance
domain should be ensured. This link will contribute to support the compliance with the point
M.A.305(e)2.(i). The AD status should therefore refer to the certificate(s) of release to
service, which refer to the items listed in GM M.A.305(6).
response

- AMC M.A.305 (c) 1. § a : the text : “For repetitive ADs or measures, only the dates of
the last and next application should be recorded in the current status” needs to be corrected
by : “For repetitive ADs or measures, only the last application in the applicable
parameter and next application should be recorded in the current status”.
Indeed, it is important to record the last performance of an AD with the adequate parameter
as required
by the corresponding AD, which is not only the calendar time.
response

AMC M.A. 305(c)1(a):”…. The AD status should include the release to service date on which
the AD or
measure was accomplished, and…”
Comment: e.g. in the case of engines, an AD on an engine part could be released first, and
the complete engine could be released much later, so does the release to service date relate
to the part or the product?
response

AMC M.A.305(c)1 Aircraft continuing airworthiness record system (a) The current status of
ADs, and measures mandated by the competent authority in immediate reaction to a safety
problem, should identify the product/component, the applicable ADs including revision or
amendment numbers and the date on which the status was updated. If the AD is generally
applicable to the aircraft or component type but is not applicable to the particular aircraft,
engine, propeller or component, then this should be identified with the reason why it is not
applicable.
In case component(s), engine, propeller is affected by the AD the status should include
engine(s), propeller(s) and components subjected to the AD i.e. the status should include
compliance with respect to each component, when more than 1 component per type is
installed, and show evidence of the aircraft applicable configuration.
The status of AD should be sufficiently detailed to identify any field loadable software which
is used for operating or controlling the aircraft
The AD status should include the release to service date on which the AD or measure was
accomplished, and where the AD or measure is controlled by flight hours and/or flight cycles
and/or landings and/or any other applicable parameter, as appropriate, it should include the
corresponding total life accumulated in service with reference to the applicable/suitable
parameter(s) on the date when the AD or measure was accomplished.
If the AD is not already accomplished i.e. the terms are not yet expired, the current status of
compliance of AD should include the next accomplishment data with reference to applicable
parameters and dates.
For repetitive ADs or measures, only the dates and applicable/suitable parameters of the last
and next application should be recorded in the current status.
The status should also specify the method of compliance and which part of a multi-part AD
or measure has been accomplished, where a choice is available in the AD or measure. When
the AD is multi-part or requests assessments of certain inspections, this information should
be shown as well.
JUSTIFICATION:
in case of more then 1 component of the same type installed it should be clear the applicable
configuration and/or status by each component installed (in line with AMC 305 c (2) e) with
reference to AD;
Added provision for field loadable software (in line with AMC 305 c (2) c)
Added provision for next due in case of 'one time AD' not yet expired;
Added provision to show that, for repetitive AD, applicable parameters (i.e AD within 6000
FH or FC or 1 yr which ever occur first or later) are not expired;
response

§3, 2nd phrase. About repetitive AD. There are some ADs followed by hours. Why should we
only follow them by date? Why don't we add "applicable parameters" and last performance
and next due.
response
p. 17-18
to Part-M): — Point AMC M.A.305(c)2

page 16/44
(8) "Other maintenance required..."
Proposal:
Please replace "other" with "additional".
Rationale:
Reading the text we think this fits better.
response

AMC M.A.305(c)2 paragraph (b)
This new AMC material replaces previous examples of substantiating data that may be
retained by the owner/operator in AMC M.A.305 (d) however the list is reduced. While it is
reasonable that detailed compliance reports generated by the DAH, and accepted by the
Authority in finding compliance, should remain proprietary the list should be expanded to
include master drawing lists (in order that completeness of the data applied to the aircraft
may be verified) and other reports that are cumulative in nature (such as electronic load
analysis).
AMC M.A.305(c)2 paragraph (c)
Further clarification is required around the term ‘field loadable software’ which implies that
the software may not be changed in maintenance shop. An alternative term would be
preferable to clarify that the intent is to refer to software that is regarded as a part or
component of the aircraft which is significant in terms of operating or controlling the aircraft
(whether the software is installed in the field or not).
AMC M.A.305(c)2 paragraph (e)
Please include further clarification regarding the components for which the status must be
known by owner/operators as indicated below (i.e. insert ‘mandatory instructions and
associated…’):
‘It is not expected to have the status of modifications and repairs per each component. This
status should include engine(s), propeller(s) and components subjected to mandatory
instructions and associated airworthiness limitations, and it is not intended that it should be
retained for other components’.
response

NPA 2014-04, pages 17-18/44, AMC M.A.305(c)2
It is proposed to amend the paragraph (a) of the AMC M.A.305(c)2 to read:
“(a) Status of current modifications and repairs means a list of modifications and repairs
embodied on since the original delivery from the Production Approval Holder/Original
Equipment Manufacturer of (and still existent upon) the aircraft, engine(s), propeller(s), or
component(s) thereof, as appropriate. The status should also list the un-repaired
damages/degradations. It should include the identification of the aircraft, engine(s), or
propeller(s), or component(s) thereof, as appropriate, and the date of the certificate of
release to service and the corresponding total life accumulated in service by the affected
item when the modification or repair was accomplished, or the un-repaired
damages/degradations assessed. The status of current modifications and repairs should
reference the pertinent certificate(s) of release to service. Where a modification or repair
creates the need for the accomplishment of repetitive scheduled maintenance tasks, the
reference to the applicable tasks from the maintenance schedule of the aircraft
maintenance programme should be added. The status should include the reference to the
data in accordance with M.A.304 that provides the accomplishment procedure for the
modification or repair. It should also specify which part of a multi-part modification or repair
has been accomplished and the method of compliance, where a choice is available in the
data.”
The instructions of the Key Risk Element C3 in the appendix III to GM1 M.B.303(b) support
the idea that the repair status should list the un-repaired damages or degradations that are
currently embodied. In addition, the status of current modifications and repairs should
record only the modifications/repairs/un-repaired damages or degradations that are still
existent: For example, a repair may be replaced by another one as a result of a larger
damage at the same location. In such a case, the initial repair should not be listed.
Reference to components in the paragraph (a) is added for consistency with the paragraph
(e) contents.
The total life accumulated in service by the affected item at the time of the
repair/modification accomplishment or of damage/degradations assessment is also added.
This information may become necessary for example to schedule future maintenance
resulting from repair re-assessment (e.g. Part-26 for ageing aircraft structure: replacement of
a repair after a number of flight hours/flight cycles due to widespread fatigue damage
considerations), and for consistency with the other statuses.
The reference to ‘repetitive’ maintenance tasks has been extended to any ‘scheduled’
maintenance task (e.g. the replacement of a repair is not necessarily repetitive, but it may
need to be scheduled).
The term ‘maintenance schedule’ (of the aircraft maintenance programme) has been added
for consistency with the wording of GM M.A.305.
A link between the continuing airworthiness management domain and the maintenance
domain should be ensured. This link will contribute to support the compliance with the point
M.A.305(e)2.(ii). The status of current modifications and repairs should therefore refer to the
certificate(s) of release to service, which refer to the items listed in GM M.A.305(6).
Note: In the AMC M.A.305(c)2, the meaning of ‘status’ is “a list of…”. In the paragraph (a) of
AMC M.A.305(c)3, the meaning of ‘status’ is “the last and next accomplishment data for…”.
Using two meanings for a single term will be a source of confusion. As a result of the
improvements introduced in the AMC M.A.305(e) on IT systems, it is probably preferable to
define this term like in the following, and to adjust the different definitions using it
accordingly:
“Within the frame of point M.A.305, ‘status’ means the data establishing the level of
compliance of an aircraft, engine, propeller, or component thereof, with a requirement. Each
status should:
(i) identify the aircraft, the engine, the propeller or the component it applies to,
(ii) be dated, and
(iii) include the relevant total in-service life accumulated in flight hours and/or flight cycles
and/or landings and/or any other applicable parameter, as appropriate, on the date of the
status.”
response

NPA 2014-04, page 18/44, AMC M.A.305(c)2

It is proposed to amend the paragraph (b) of the AMC M.A.305(c)2 to read:
“(b) The data may include:
[…]
(4) aircraft maintenance programme changes and instructions for continuing continued
airworthiness; and/or
[…]”
The terms ‘aircraft maintenance programme’ and ‘instructions for continued airworthiness’
have been used for consistency with the titles of point M.A.302 and point 21.A.449 (and
21.A.61, 21.A.107, and 21.A.120), respectively.
response

NPA 2014-04, page 18/44, AMC M.A.305(c)2
It is proposed to amend the paragraph (c) of the AMC M.A.305(c)2 to read:
“(c) The status of modifications should be sufficiently detailed to identify any installed field
lLoadable sSoftware Aircraft Part (LSAP) which is used for operating or controlling the
aircraft, whose Part Number evolves independently of the target hardware aircraft part, as
identified in the instructions for continued airworthiness of the relevant design approval
holders. A field loadable software can be loaded without removal of the equipment from
the aircraft or engine. Other types of field lLoadable software parts not used for operating
or controlling, such as navigational data bases or entertainment systems, are not considered
under this recording requirement.”
The control of software part configuration is more and more important with the introduction
of new technologies. Therefore, the initiative that has led to the introduction of this
paragraph is strongly supported.
Some competencies pertaining to the design domain are required to establish the list of
software parts for which configuration control is necessary: should the design approval
holders be not involved, some important software parts could be missed, or conversely, the
list could create an unnecessary burden on the person or organisation responsible for the
aircraft continuing airworthiness. Therefore, a provision referring to the instructions for
continued airworthiness of the relevant design approval holders is essential.

The term ‘Loadable Software Aircraft Part (LSAP)’ is preferred to ‘Field Loadable Software
(FLS)’ as this latter may unfortunately suggest that software parts loaded in shop are not
covered. It is reminded that FLS is defined as any loadable software that is designed to be
loaded on the aircraft without removal of the target hardware from the aircraft.
Both terms LSAP and FLS can be found in the ARINC 667 classification of loadable software.
In addition, the use of ‘Loadable Software Aircraft Part’ reminds to the reader that some
software parts are aircraft parts. The Article 3 of the Regulation (EC) 216/2008 defines the
term ‘parts and appliances’:
QUOTE
‘parts and appliances’ shall mean any instrument, equipment, mechanism, part, apparatus,
appurtenance, software or accessory, including communications equipment, that is used or
intended to be used in operating or controlling an aircraft in flight; it shall include parts of an
airframe, engine or propeller, or equipment used to manoeuvre the aircraft from the ground.
UNQUOTE
response

NPA 2014-04, page 18/44, AMC M.A.305(c)2
It is proposed to amend the paragraph (e) of the AMC M.A.305(c)2 to read:
“(e) It is not expected to have the status of modifications and repairs per each component.
This status should include engine(s), propeller(s) and components subjected to mandatory
instructions and associated airworthiness limitations, and it is not intended that it should be
retained for other components.”
To be consistent with the wording used in Key Risk Element A2 in the appendix III to GM1
M.B.303(b).
response

We suggest to add item (f) to AMC M.A.305(c)2 :
‘The list of embodied repairs should at least contain the following parameters for each single
repair-entry:
· Description of repair (e.g., patch, blend, crack, dent)

· Location of repair (e.g., reference to stringers, frames, lefthand/righthand)
· Reference to approved maintenance data (substantiation documentation: reference data
such as DTA, EASA/DOA minor repair approval, SRM).
· Supplemental inspections and limitations, if applicable.
· Date of accomplishment of the repair.
· Optional parameters are for example:
o Reference to damage report.
o Reference to accomplishment instructions.
o Reference to instruction for continuing airworthiness.
o Dimensions of repair.
o Number of flight cycles/hours at the date of accomplishment of the repair.
o Operator specific parameters.
The use of a chart showing the top / side view identifying the location of the damages and
repairs (a.k.a. a Dent & Buckle Chart) is recommended.’
Explanation:
To provide clarification and AMC.
response

- AMC M.A.305 (c) 2 § a : concerning the repair status, it could be useful to identify the
category of the repair (permanent, interim or temporary). It is also important to
demonstrate adequate follow-up easily. The record of the follow-up is necessary in case of
repetitive inspection but also in case of interim repair or temporary repairs that can request
actions within a specific time frame with short term repetitive inspection or without any
repetitive inspection. In these circumstances, it could be interesting to include in this AMC
the necessity to record the information of applicable parameter when the repair is
performed and the next due or the limitation in case of interim repair.
- AMC M.A.305 (c) 2 § a : for the modification, it could be useful to refer to the applicable
maintenance data and not only to the “accomplishment procedure”. Indeed, it is important
to take into account the ICA and particularly the document containing the requirements in
term of scheduled maintenance to ensure adequate follow-up. Moreover, in the text, it
could be better to replace the wording “repetitive maintenance tasks” by “scheduled
maintenance tasks”. Indeed, for modifications and for repairs, it is possible to have a one-
time inspection or an hard time limitation.
response

-AMC M.A.305 (c) 2 § b : the reference to the “Master Drawing List or equivalent” could be
added. Indeed, this document is necessary to have an overview about the impact of a
modification on the continuing airworthiness (ex : applicable ICA). It is also important to
include the approval document (STC approval, DOA approval, Repair Approval,…).
Concerning the item (4), it could be useful to put the reference to the “instructions for
continuing airworthiness” in a specific item to be in line with the general definition of an ICA
given in the PART-21. Indeed, the ICA is not only related to document containing the
scheduled maintenance tasks required for the maintenance program but also the WDM, IPC,
AMM, SRM,…It could be put in item (3) with example of SRM, AMM,… Perhaps, for clarity it
could be better to split this article in two sections : one for the modification related data and
one for the repair related data.
response
AMC M.A. 305(c)2 point (b)
We are seeing increasing emphasis of regulators looking at the electric load analysis (ELA) of
the aircraft, which makes sense given the increasing importance of the electrical systems in
modern aircraft (A350, B787). Therefore I encourage to expand the list to also include the
ELA.
response
AMC M.A.305(c)2 point (c)
Please provide a more precise definition of field loadable software. A number of different
terms is used, sometimes with the same, sometimes different meaning (e.g. "software part
no", "loadable software aircraft part", etc.). The definition as given in the current text is a bit
vague, since a FLS can also be loaded during a shop visit of the component and then also has
to be included in this status.
response
M.A. 305(c)2 point (e)
It should be clarified which kind of airworthiness limitations are meant, e.g. compliance with
airworthiness directives.
response

AMC M.A. 305(c)2(a)
Suggested text: where a modification or repair creates the need for the accomplishment of
repetitive maintenance tasks, this should be noted.
response

AMC M.A. 305(c)2(c):
Comment: add the word “such” as shown below:
“A field loadable software can be loaded without removal of the equipment from the aircraft
or engine. Other types of field loadable software not used for operating or controlling, such
as navigational data bases or entertainment systems, are not considered under this
recording requirement.”
response

AMC M.A. 305(c)2(d)
Comment:
The text “For the purpose of recording modifications in accordance with the current
paragraph” is unclear.
Please specify “the current paragraph”.
response

AMC M.A. 305(c)2(e)
Comment:
The text “It is not expected to have the status of modifications and repairs per each
component” could suggest that the status of modifications and repairs is not expected to be
recorded for individual components. This is unclear and appears to be in contradiction with
the next sentence: “This status should include engine(s), propeller(s) and components
subjected to airworthiness limitations, and it is not intended that it should be retained for
other components”, which implies that the status of modifications and repairs on all
individual components listed in the airworthiness limitations must be recorded.
Please specify clearly that the status of modifications and repairs should only be recorded for
engine(s), propeller(s) and components that are listed in the airworthiness limitations. If this
is not the intent of the proposed text, then please clarify otherwise.
response

AMC MA305 c2 (e) 1st phrase is not necessary as it may create trouble. Can we remove it or
putting it at the end?
response

Item (b) (4)
This item may be beyond the scope of this NPA: There are differences in the definitions of
Instructions for Continuing Airworthiness between EASA and FAA. It will be very useful for
the whole industry if these definitions are harmonized.
response

AMC M.A.305(c)2 Aircraft continuing airworthiness record system
This makes reference to "instructions for continuing airworthiness". We believe this should
read "instructions for continued airworthiness", as used in Part-21 and various Certification
Specifications, e.g. CS-25.
response
response

Vor dem Hintergrund zu erwartender Erleichterungen im Rahmen der „Road Map General
Aviation“ zu restriktiv. Die EASA hat erkannt, dass insbesondere der Bereich des Luftsportes
derzeit überreguliert ist. Die komplette Anwendung des AMC in diesem Punkt bringt
keinerlei Erleichterung oder Vereinfachung, solange die lange angekündigten CS „Standard
Changes und Repair“ nicht wirksam werden.
response
p. 18
to Part-M): — Point GM M.A.305(c)2

AMC MA 305(c)2 (d):
1. "For the purpose of recording modifications in accordance with the current paragraph, a A
component replaced by a fully interchangeable alternate component is not considered a
modification, if this condition is published approved by the design approval holder (DAH). or
in the case of instruments and avionics is qualified to the same or higher ETSO/TSO or is
equivalent from a Form-Fit-Function analysis."
For GA, the DAH rarely issues interchangeability information for avionics and other
components installed after aircraft delivery. Therefore a "Form-Fit-Function" and TSO/ETSO
criteria should be considered. Many e.g. older radios are no longer available, and the
available replacement item often fits straight in to the existing rack or fittings without any
modifications at all. This type of replacement of components should not be considered a
modification in any context at least for ELA-2 and below and for non-IFR required
components.
2. The word "published" could stop DAH approvals via e-mail and limit such approvals to
manual revisions, which typically happens every six months.
response

Please consider alternate term to Field Loadable Software (see related comment in AMC
M.A. 305 (c) 2)
response

NPA 2014-04, page 18/44, GM M.A.305(c)2
Could the Agency clarify the GM M.A.305(c)2? What is the objective of this GM?
It is proposed to amend the GM M.A.305(c)2 to read (if the following fulfils the initial
objective of this GM):
“The status of modifications embodied could may include:
(a) The Llist of the installed physical components,
(b) The Llist of installed incorporeal componentsother modifications not covered by the
previous point.
When aircraft require a specific field lLoadable sSoftware Aircraft Part (LSAP) configuration
to function operate correctly, a specific listing with this information may be necessary too.”
The paragraph (b) refers to “other modifications not covered by the previous point”, but the
previous point (seemingly the paragraph (a)) refers to “the installed components”. These
paragraphs do not refer to items of the same nature, making the meaning of this GM difficult
to understand.
response

GM M.A. 305(c)2
Comment:
The text is not clear.
GM M.A. 305(c)2 paragraph (a) proposes that the status of modifications could include a list
of the installed components, while according to (b) a “list of other modifications not covered
by the previous point” should be included.
Under (b) it is not clear what is meant by “other modifications”, because (a) only requires a
list of components and not of modifications.
Under (b) it is not clear what is meant by “the previous point”, most likely this GM M.A.
305(c)2(a), but this is not clear. If “the previous point” refers to GM M.A. 305(c)2(a), then
that implies that all modifications must be recorded, and not only those listed in the
airworthiness limitations.
It is suggested re-write this paragraph to clearly state the intent. The intent of this paragraph
should be in-line with the intent of AMC M.A. 305(c)2(e).
response
GM M.A. 305(c)2
Comment:It is actually proposed to delete this guidance. It will only create confusion.
response

DGAC France believes that the « software » configuration is properly identified, either
through the part number component in which it is loaded, or by other means such as a major
change to download a new revision of software. The software is not a material that can be
checked without proper tools. The sentence “when aircraft require a specific field loadable
software configuration to operate correctly” is too vague.
The GM is only understood when read with and after the AMC M.A.305(c)(3) point (e).
Maybe the mentioned (e) might be expanded, so the GM is not needed at all.
DGAC believes this GM does not add much clarification and recommends this GM to be
deleted.
response

Service bulletins, AD and taskcards. Sometimes may be confusing and difficult to find,
identify, the work to be done, witch aircraft in your fleet is to be done, which in turn can lead
to mistakes being made. They should be clear, including aircraft S / N.
then you got the taskcard the layout must provides an easy overview and clear, natural
signature field / stop during the work. Many different skills/professionals may be involved.
Work cards where you with simple glance can see what to do and natural stop with clear
signing point (easier control of work done) will promote safety and human factor, lot of the
work is performed at night. It is also better that everything comes out clearly from the
factory than it is adjusted/designed at each airliners engineering office.
The creation of computer systems that are easy to use must higher up the agenda.
this is a general response.
response

It is not clear as to what GM M.A.305(c)2 Aircraft continuing airworthiness record system
relates.
Is this providing an explanation to AMC M.A.305(c)2 or the requirement M.A.305(c)2 itself?

There is no direct reference to "The status of modifications embodied" in either the
(proposed) regulation or AMC.
It is not clear as to what (a) List of the installed components could mean or how it should be
applied.
It is not clear as to what (b) List of other modifications not covered by the previous point
could mean. What is "the previous point"?
Guidance Material must clearly relate to current rule material and should be clear in its
meaning.
Without knowning the answers to the above, we are not is a position to suggest an
alternative at this time.
response
p. 18-19
to Part-M): — Point GM M.A.305(c)3

(b) : Replace "For repetitive tasks, only the date of the last ...." by "For repetitive tasks, only
the applicable parameters at the date of the last ...."
response

NPA 2014-04, page 17/44 and following, AMC M.A.305(c)3 (as well as AMC M.A.305(c)1 and
2)
Could the Agency clarify the calendar reference for task accomplishment to be stated in the
different reports required by point M.A.305(c)? Is it the date the task is completed or the
date the certificate of release to service is issued (taking into account both cases, aircraft
maintenance and component maintenance)?
In addition, could the Agency clarify the correct course of actions to take when new/revised
maintenance data (point M.A.401/point 145.A.45) are issued during the period defined by
the date the work order is issued, and the date the certificate of release to service is issued?
Can compliance be declared in reports required by the point M.A.305(c) when former
maintenance data have been used?
The calendar reference is essential to calculate the next accomplishment of repetitive

maintenance tasks:
- Aircraft maintenance: a number of aircraft maintenance tasks may be completed, and the
corresponding release to service may be issued 6 months later (e.g. heavy maintenance
checks requiring extensive downtime).
- Component maintenance: the installation on aircraft of a serviceable landing gear sliding
tube following the detection of a shock absorber leak (the replacement part has been stored
for 15 months after overhaul). Which date is the reference to schedule the next overhaul:
the date of the last overhaul (*), the date of storage (storage or re-commissioning?), or the
date of installation on aircraft (**)?
(*) date of overhaul completion or date the certificate of release to service is issued?
(**) date of installation completion or date the certificate of release to service is issued?
It may have a significant impact on the next due. The AMC should provide explicitly the
reference date in order to eliminate ambiguity and resulting non-compliances.
Maintenance data revision cycles (Part-21 process) interfere inevitably and regularly with on-
going maintenance checks (Part-M/Part-145 process). How should new/amended
maintenance data (e.g. the Aircraft Maintenance Manual) be managed when they are
received after the issuance of the work order or after tasks completion, but before the date
the certificate of release is issued? Does a given task need to be performed again in
accordance with the new/amended maintenance data because the certificate of release to
service has not been issued yet? The persons creating these statuses/reports ask themselves
the question “can compliance be declared (in the report)?”. The AMC should provide
explicitly the correct course of actions to take in such situations in order to eliminate this
ambiguity, resulting non-compliances, and recurring questions.
Note: for consistency of contents, these comments have taken the date the certificate of
release to service as the reference.
response

NPA 2014-04, pages 18-19/44, AMC M.A.305(c)3
It is proposed to amend the AMC M.A.305(c)3 to read:
“(a) The current status of compliance with the aircraft maintenance programme means the
last and next accomplishment data for the scheduled tasks specified in the aircraft
maintenance programme. It should include:
(i) an identifier specific enough to allow an easy and accurate identification of the task to
be carried out, such as a task reference combined with a task title or short description of
the work to be performed,
(ii) Accomplishment data pertinent to the engine, propeller or component should be stated
when a task is controlled at the engine, propeller, or component level.the engine,
propeller, or component identification (Part Number and Serial Number) when the task is
controlled at the engine, propeller, or component level,
(iii) the date when the task was accomplished (the date the certificate of release to service
was issued) and for repetitive tasks when it is due next time, as well as the terminating
action when it is performed, and
(iv) the reference of the certificate of release to service showing the demonstration of
compliance.
The current status of life limited components and the current status of time controlled
components may not be included, but referenced in the current status of compliance with
the aircraft maintenance programme.
(b) Where the task is controlled by flight hours and/or flight cycles and/or landings and/or
calendar time and/or any other applicable parameter, the total in-service life accumulated by
the aircraft, engine, propeller or component (as appropriate) in the suitable parameter(s)
should also be included. For repetitive tasks, only the date of the last and next applications
should be recorded, as well as the terminating action when it is performed.”
The definition of the current status of compliance with the aircraft maintenance programme
should provide a similar level of details as for the current status of ADs, and measures
mandated by the competent authority in immediate reaction to a safety problem (for
example).
The GM M.A.305 states that “A ‘life limited part’ is a part for which the maintenance
schedule of the aircraft maintenance programme requires…” and “The term ‘time controlled
components’ embraces any component for which the maintenance schedule of the aircraft
maintenance programme requires…”.
A clarification is added to prevent the duplication in the current status of compliance with
the aircraft maintenance programme of data already provided in the current status of life
limited parts and in the current status of time controlled components. Further, the (partial or
complete) duplication of regulation requirements creates hazards (potential future
contradictions between requirements, confusion, etc.) and makes the compliance
demonstration more complex than necessary. The duplicated data in the different status
mentioned here above could contradict each other and create confusion.
response

AMC M.A.305 (c) 3 § (b) : the text : “For repetitive tasks, only the date of the last and next
applications should be recorded, as well as the terminating action when it is performed.”

needs to be corrected by : “For repetitive tasks, only the last and next applications in the
applicable parameter should be recorded, as well as the terminating action when it is
performed.” Indeed, it is important to record the last performance of a task with the
adequate parameter as required by the corresponding aircraft maintenance program task,
which is not only the calendar time.
response

AMC M.A. 305(c)3 (b)
Comment: What type of components would require recording of “total in-service life”? Life –
limited components we presume.
response

AMC M.A.305(c)3 Aircraft continuing airworthiness record system (a) The current status of
compliance with the aircraft maintenance programme means the last and next
accomplishment data (referring to the applicable parameter) for the scheduled tasks
specified in the aircraft maintenance programme. Accomplishment data pertinent to the
engine, propeller or component should be stated when a task is controlled at the engine,
propeller, or component level.
(b) Where the task is controlled by flight hours and/or flight cycles and/or landings and/or
calendar time and/or any other applicable parameter, the total in-service life accumulated by
the aircraft, engine, propeller or component (as appropriate) in the suitable parameter(s)
should also be included. For repetitive tasks, only the date and suitable parameters of the
last and next applications should be recorded, as well as the terminating action when it is
performed.
JUSTIFICATION: last and in particular next due should be related and shown referring to the
applicable parameters
response

a) why it is should and not shall? from our point of view, it is stronger than should.
b) on the last sentence "date" should be replaced by "applicable parameters" as for
Repetitive ADs; and "should" replaced by "shall".
response
p. 20-21
to Part-M): — Point GM M.A.305(d)2

para (c)2. - there appears to be a misunderstanding of the terms "on condition" and
"condition monitoring" such that these terms are effectively transposed. Heading should be "
2. Condition Monitoring ". "On Condition" is the fly-to-failure condition.
response

GM MA 305(d)(2) (c):
(2) On-Condition
"It is a preventive.... failure in service"
Note: Components which are not time controlled are instead subject to Condition-
Monitoring. These components are permitted to remain in service without preventive
maintenance until functional failure occurs (i.e. they are "fly-to-failure")
May be replaced by something similar to this (from FAA): MSG-2 introduced condition
monitoring.This process is for systems, components, or appliances that have neither HT nor
OC maintenance as their primary maintenance process. It is accomplished by appropriate
means available to an operator for finding and solving problem areas.The user must control
the reliability of systems or equipment based on knowledge gained by analysis of failures or
other indications of deteriorations.
Turbine engines are frequently operated under various Condition-Monitoring systems where
engine parameters are downloaded and analysed in real time to find problems before they
occur and to find the economically optimum time of removal for refurbishment of modules.
They definitely do not "fly to failure".
response

GM M.A.305(d)(2) add item (3) in place of Note:
Please revise the sentence to be clearer as indicated below:
‘(3) Note: Condition Monitoring
Components which are not time controlled are instead subject to Condition-Monitoring.
These components are permitted to remain in service without preventive maintenance until a
functional failure occurs (i.e. they are ‘fly-to failure’).’
response

NPA 2014-04, page 20/44, GM M.A.305(d)(2)
It is proposed to modify GM M.A.305(d)(2) to read:
“The maintenance schedule of the aircraft maintenance programme may require:
(a) the removal of a component for periodic restoration in a suitable approved workshop to
return the component to a specified standard (e.g. removal of landing gear for overhaul);
(b) the periodic replacement in a suitable approved workshop of a component by a new one
when it is not possible to restore the item to a specific standard of failure resistance (e.g.
discarding of filters universal joints of a gearbox, batteries, discharge cartridges of fire
extinguishers, etc.);
(c) a quantitative inspection performed in a suitable approved workshop to confirm
periodically that a component meets specified performance standards (e.g. functional check
of aileron hinge bearings for excessive play the portable emergency locator transmitter,
inspection of the portable VHF transceiver, functional check of emergency exit locking
mechanism the elevator servocontrol relief valve, etc.). The component is left in service (no
further maintenance action taken) on the condition that it continues to fulfil its intended
purpose within specified performance limits until next scheduled inspection.
Components subject to the above maintenance schedule requirements are termed ‘time
controlled components’.
Note: The maintenance in accordance:
– with (a) and (b) assumes a predictable deterioration of the component: the overall
reliability invariably decreases with age; and
– with (c) assumes a gradual deterioration of the component: failure resistance can reduce
and drop below a defined level.
The maintenance period is controlled at component level. […]”
The examples chosen are potentially misleading (e.g. is it necessary to remove the aileron
from the aircraft to perform the functional check?). New examples are proposed.
The last sentence in paragraph (c) is extracted so that it applies to the paragraphs (a) to (c).
Consistency with the comment on the paragraph (4) of the GM M.A.305 has been checked.
response

NPA 2014-04, pages 20-21/44, GM M.A.305(d)(2)
It is proposed to modify GM M.A.305(d)(2) to read:
“[…]
For aircraft maintenance programmes developed under a primary maintenance process
oriented methodology (e.g. Maintenance Steering Group-1 (MSG-1) or MSG-2), the term
‘time controlled component’ applies pertains to the ‘Hard Time’ components and ‘On-
Condition’ components primary maintenance processes. Such terms mean:
(1) Hard Time
This is a preventative preventive process in which known deterioration of a component is
limited to an acceptable level by the maintenance actions which are carried out at periods
related to time in service (e.g. calendar time, number of cycles, number of landings). The
prescribed actions return the component to its original condition.
(2) On-Condition
It is a preventive process in which the component is inspected or tested, at specified periods,
to an appropriate standard in order to determine whether it can continue in service. The
purpose is to remove the component before its failure in service.
(3) Note:Condition Monitoring
This is a process in which a parameter of condition in a component (vibration,
temperature, oil consumption, etc.) is monitored to identify the development of a fault.
Components which are not time controlled are instead subject to Condition-Monitoring.
These components are permitted to remain in service without preventive maintenance until
a functional failure occurs (i.e. they are ‘fly-to-failure’).
Note: For components that are not subject to any of these primary maintenance processes,
corrective maintenance is carried out after failure detection and is aimed at restoring
components to a condition in which they can perform their intended function (‘fly-to-
failure’).”
Could the Agency confirm the term in the definition of ‘maintenance’ under which ‘test’
falls?
For sake of consistency, either the term ‘preventative’ or the term ‘preventive’ should be
used rather than both in these definitions.
Different definitions may be found in various locations of Regulations:
– The paragraph (h) of the Article 2 of the Regulation (EC) No 2042/2003 defines the term
‘maintenance’:
(h) ‘maintenance’ means any one or combination of overhaul, repair, inspection,
replacement, modification or defect rectification of an aircraft or component, with the
exception of pre-flight inspection.
No reference to ‘test’ is made.
– The Appendix II – Authorised Release Certificate EASA Form 1 defines the following terms:
(i) Overhauled. Means a process that ensures the item is in complete conformity with all the
applicable service tolerances specified in the type certificate holder’s, or equipment
manufacturer’s instructions for continued airworthiness, or in the data which is approved or
accepted by the Authority. The item will be at least disassembled, cleaned, inspected,
repaired as necessary, reassembled and tested in accordance with the above specified data.
(ii) Repaired. Rectification of defect(s) using an applicable standard (*).
(iii) Inspected/Tested. Examination, measurement, etc. in accordance with an applicable
standard (*) (e.g. visual inspection, functional testing, bench testing etc.).
(iv) Modified. Alteration of an item to conform to an applicable standard (*).
* Applicable standard means a manufacturing/design/maintenance/quality standard,
method, technique or practice approved by or acceptable to the Competent Authority.
– The point 21.A.431(c) in the Part-21 defines a repair:
(c) A ‘repair’ means elimination of damage and/or restoration to an airworthy condition
following initial release into service by the manufacturer of any product, part or appliance.
So is a test an inspection? If it is an inspection, what are the particularities of a test
compared with the other inspections?
For sake of consistent editorial rules, an item (3) should be introduced for ‘condition
monitoring’ instead of using a note in the item (2) ‘on-condition’. This would improve the
readability of this paragraph.
The definition of Condition Monitoring proposed in the NPA may give the impression that
Condition Monitoring needs to be implemented for all components not addressed by the
first two primary maintenance processes (Hard Time and On-Condition). In fact, such a
monitoring is expensive and is therefore only recommended for some components (e.g.
engines). Further, it may also give the impression that no proactive action is to be done
under the Condition Monitoring primary maintenance process: This process generates no
scheduled maintenance task but gives the possibility to arrange for maintenance or take
other actions in anticipation of failure in order to avoid its consequences.
Although the intent is understood, the wording “(i.e. they are ‘fly-to failure’)” at the end of
the definition may be misleading, as the objective under Condition Monitoring is to avoid a
failure. This justifies the need for the note: the components not subject to any primary
maintenance process are subject to corrective maintenance (‘fly-to-failure’).
response

We suggest to add an Appendix XII to AMC M.A.305(d) or to supply this template in the form
og GM
Proposal:
Propose to provide a template for an ‘in-service history card’ . Template to be developed in
the working group, taking into account existing practices and other authority templates
currently in use.
Explanation:
To create an standard as guidance material.
response

GM M.A.305 (d) (2):
Any maintenance handbook for aircrafts have specific check items for many several parts.
The period for the checks are defined very clear. I think that there is no further need for a
definition for check some parts, e.g. aileron hinge.
Do you do such quantitative inspections at your vehicle? Remember: Very critical are the
hinges in the steering column!
response

GM M.A.305 (d) (2) (c): "Components subject to the above maintenance schedule
requirements are termed 'time controlled components.'"
-> (a) to (c) is affected -> text has to be shifted.
This is important, because (b) includes components like filters and cartriges that should be
treated as 'just time controlled' with maintenance task "discard". Named components are
not part of the Airworthiness Limitation Section.
response

GM M.A. 305(d)2
Comment: we perceive a “philosophy-change” introduced with this GM in the Aircraft
continuing airworthiness record system: a move is made from following/tracking and tracing
on aircraft level to component level
response

GM M.A. 305(d)2(b) :
Comment: GM M.A. 305 (4) refers to “current status of time controlled components” . Items
mentioned in GM M.A.305(d)(2)(b) could just as well be categorized in Life Limited Part,
because permanent removal from service before limit in AMP is reached is required.
response

GM M.A.305 (d) (2) (c): "Components subject to the above maintenance schedule
requirements are termed 'time controlled components.'"
-> (a) to (c) is affected -> text has to be shifted.
This is important, because (b) includes LLP's like filters and cartridges that should be
treated as 'just time controlled' with maintenance task "discard". Named components are
not part of the Airworthiness Limitation Section.
response

This GM is named as “aircraft continuing airworthiness record system”. It is a very clear and
useful GM. But it is mainly describing some tasks of maintenance to be performed, in order
to check and change components that are sensible to ageing issues. It is more linked to
details about M.A.301 point 3.
it seems to DGAC France it would be better attached to M.A.301 point 3.
Rename GM M.A.305 (d)(2) into GM M.A.301 and name it as “accomplishment of
maintenance for time controlled components”
response

In § (1), in the sentence : “The prescribed actions return the component to its original
condition.”, the term “original condition” is not very precise: it could be understood as its
status as a brand new component, it could be understood as the status it had at previous
check. It might be better to say the actions aim at restoring the airworthiness margin
Modify as suggested :
The prescribed actions return restore the component margins regarding to the applicable
time limitations to its original condition.
response

At the end of the (c) subparagraph, there is a kind of definition “Components subject to the
above maintenance schedule requirements are termed time controlled components”. This is
redundant (and hopefully equivalent) with the definition of components within GM.M.A.305
item (4) page 15.
It is therefore recommended a slight modification here as follows to avoid a double
definition:
(c)… scheduled inspection.
Note: Those three type of actions may be applied for Components subject to the above
maintenance schedule requirements are termed time controlled components as defined in
GM.M.A.305 item (4).
response

In the definition of GM M.A.305(d)(2) we oppose the usage of the cited examples.
In the way it is written, first of all it is indicated (or at least implied) that a "time controlled
component" should be mentioned in the maintenance schedule of an AMP.
Then three examples are given.
Examples (a) and (b) are equivalent to the well established practices for life limited / service
life limited parts.
Example (c) is another thing - this example of a regular check at aileron hinges for play moves
now many parts and components into the realm of "time controlled parts".
If this then consequently implies that all these parts need now mention in the AMP we have
reached a situation, where a simple change in the GM triggers requests by NAAs for
accordingly amended AMPs for literally tens of thousands of aircraft in Europe.
This is not acceptable.
In the case of small aircraft maintenance manuals heve been written (and approved by the
authorities) which contain the information to safely maintain and service the aircraft. We
oppose any effort by EASA or other authorities to move the content of these maintenance
manuals into the AMPs because this is a paper exercise which creates effort without safety
benefit. It also creates costs as these AMPs need approval.
We have already seen examples where NAAs requested to list a monthly check and
lubricating of a door seal in the AMP!
It is acceptable to use the AMP to remind the owner / operator / maintainer to remind about
parts which have a limited (calendar or service) time for use, but please do not require to
copy-paste all listed checks in a maintenace manual into the AMP.
response

page 20/44
GM M.A.305(d)2 Aircraft continuing airworthiness record system
The provisions proposed do not fit for operations with non-complex aircraft in a VMC/VFR
sports and recreational environment. We oppose therefore to any integration of the
contents of maintenance manuals of these aircraft into the AMP's.
Rationale:
If it fits CAT it definitely not fits our segment of General Aviation. It is a pure "paper exercise"
without any safety benefit, only adding costs.
AMP's reqduire approval, this is not for free. Within our community the more money we are
obliged to spend on documents we do not need means the less money is availble for flying,
the lower the training, the lower the safety of flight. Not only states suffer from budget
constraints...
response

GM M.A.305(d)(2) Aircraft continuing airworthiness record system
This text provides a useful explanation of the philosophies behind MSG-1 and MSG-2 based
maintenance programmes. However most large transport aeroplanes have maintenance
programmes based upon MSG-3, which does not embrace the same termonology.
Does this mean that this text is ONLY applicable to MSG-1 and MSG-2 programmes? If so,
where is the parallel guidance for MSG-3 programmes?
Is it the intention of EASA to consider all those MSIs with scheduled maintenance tasks as
"time controlled components"? If so, we believe the combination of this GM and the new
M.A.305(e) 3 requirements will add a significant burden to industry in terms of increased
data segregation and retention, no matter how well intentioned.
response

The trailing sentence of this chapter will create a lot of additional "time controlled
components" which some NAAs will subsequently ask to be included in the Maintenance
Programm, such as valve tappet, ignition contactors, carburetor needles and seats, .....
This is again additional paperwork without any benefit because all these items are listed in
the check lists of the TCH and must not be listed in another document again.
response

Der Versuch der Unterscheidung bei „laufzeitkontrollierten Komponenten“ nach Ablaufzeit
(Hard Time) und Zustandsüberwachung (On-Condition) ist zunächst einmal ein logischer
Ansatz. Fraglich ist die Einstufung durch die zuständigen Behörden. Das Beispiel eines Motors
in einem Luftfahrzeug <2t wird dadurch noch immer nicht beantwortet.
Ein Hersteller EMPFIEHLT im Normalfall sowohl eine Limitierung sowohl nach Kalenderzeit
(Jahre) wie auch nach Zyklen (Flugstunden). Wer legt nach dieser NPA fest, welche Angabe
„Hard Time“ und welche „On-Condition“ ist, solange der Hersteller nur eine Empfehlung
ausspricht?
response
p. 21-23
to Part-M): — Point AMC M.A.305(e)
comment 16 comment by: Stefan Stroeker

Regarding AMC M.A.305(e) - Aircraft continuing airworthiness record system, there is the
need of additional Guidance Material (GM) given. CAMO's could implement these IT system
based requirements better when having more explanation, e.g. possibilities of data transfer
techniques like Migration of Flat Files/Use of Interface Modules or how to track any change
of aircraft continuing airworthiness records.
Many thanks and best regards, Stefan Ströker
response
(g) : Replace "The reconstructed records should be submitted...." by " If incomplete

reconstruction, the statement should be submitted....." because we consider that acceptance
from authority is not necessary if full reconstruction is done.
response

page 22/44
(f) Digitised Record Retention
"The system used...must...":
Question:
Does this "must" fit with the usual way "must", "shall", "should" are used in the text?
response

AMC M.A.305(e) paragraph (c):
The topic of this section would appear to be better described as ‘Form of Records’ with some
amendments to the related text. The following minor amendment is proposed:
“(c) Form of records keeping:
Producing and/or keeping continuing airworthiness records in a form acceptable to the
competent authority normally means in either material/physical or electronic state, or a
combination of both.
(1) original paper document or secured set of electronic data as the original form (either
paper or via an approved electronically signed form), or
(2) a paper reproduction of a paper document (original or copy), or
(3) an electronic reproduction of a secured set of electronic data (original or copy), or
(4) a printed reproduction of a secured set of electronic data (original or copy), or
(25) as an electronically digitised reproduction copy of the original a paper document form
(original or copy), or
(36) as a microfilm or scanned reproduction copy of the original a paper document form
(4) as a paper form where the paper record is a printed reproduction of an original form from
either (1), (2) or (3) above.
Where IT systems are used to retain documents and data, it should be possible to print a
paper version of the documents and data kept.”

AMC M.A.305(e) paragraph (e):
Please amend the section to consider that a digitised record may be made from a copy as
well as an original. The following minor amendment is proposed:
“(e) Digitised Records:
Digitised records may be created from an original a paper record document (original or copy)
or as a digital electronic original secured set of electronic data. When created from an
original a paper record document:
(1) the creation date of the digitised record should be stored with the digitised record,
(2) it is advisable to create an individual digitised record for each original document, and
technology should ease the future retrieval of the record.”
AMC M.A.305(e) paragraph (f):
This section describes the security of digitised records and the security principal is generic
and should apply irrespective of form of the source data. The following minor amendment is
proposed:
“(f) Digitised Record Retention:
Digitised records when created from an original a paper record document, or as a digital
electronic original secured set of electronic data, should be stored on a system which is
secured and kept in an environment protected from damage (e.g. fire, flooding, excessive
temperature or accidental erasing). […]
The system used for retention of digitised records must:
1. Ensure the integrity (whatever the record creation form) and accuracy of the record (when
created from an original a paper record document).
2. Ensure that access to the digitised record has safeguards against alteration of the data.
3. Provide assurance that the data has not been modified after creation.
[…]
Computer backup discs, tapes etc., should be stored in a different location from that
containing the current working discs, tapes, etc., and in a safe environment. Where the
competent authority has approved a system for digitised record keeping satisfying the above,
the original paper record document may be permanently disposed of.”
response

NPA 2014-04, page 21/44, AMC M.A.305(e)

Could the Agency clarify the reasons why the term ‘other’ is used in the paragraph (a) and (b)
of the AMC M.A.305(e)?
Should the paragraph (a) read the following?
“(a) The information that constitutes the aircraft continuing airworthiness records may be
entered in an information technology (IT) system and/or other documents equivalent in
scope and detail.
[…]
(b) ‘Other dDocuments equivalent in scope and detail’ could be an aircraft logbook, a
technical logbook, engine logbook(s) or engine module log cards, propeller logbook(s) and
log cards for life limited parts and time controlled components. […]”?
For sake of understanding. It is not clear why the term ‘other’ has been used. It seems to
imply that an IT system is a system of documents.
The technical logbook to show compliance with the point M.A.305(b)3. is missing in the
paragraph (b).
response

NPA 2014-04, pages 21-22/44, AMC M.A.305(e)
It is proposed to modify the paragraph (b) of the AMC M.A.305(e) to read:
“[…]
Any logbook/logcard should contain:
(1) Identification of the product, part or component it refers to;
(2) Type, part number, serial number and registration, as appropriate, of the aircraft, engine,
propeller, engine module, or particular component to which the particular individual
component has been fitted, along with the reference to the installation and removal;
(3) The date and the corresponding accumulated total life in flight time hours and/or flight
cycles and/or landings and/or calendar time and/or in any other applicable measurement
unit, as appropriate; and
(4) Any AD, modification, repair, maintenance or deferred maintenance tasks applicable.
If fulfilling the applicable requirements, a logbook/log card as described above could be a
means to comply with the current status of life limited parts and time controlled
components and/or the in-service history record for each life limited part.”
The term ‘part’ is covered by the term ‘component’ as defined in the Regulation (EC) No
2042/2003 (paragraph (c) of the Article 2).
Reference to ‘part number’ is added for the identification of components.
The term ‘particular component’ is already used and defined in the proposed amendments
of the AMC M.A.305(b)1. Consistency is necessary.
The current proposed amendment does not take into account the possibility of
measurement units other than those listed, for example cycles of APU usage.
response

NPA 2014-04, page 22/44, AMC M.A.305(e)
It is proposed to modify the paragraph (c) of the AMC M.A.305(e) to read:
“[…]
(c) Form of records keeping:
Producing and/or Kkeeping continuing airworthiness records in a form acceptable to the
competent authority normally means in either material/physical or electronic state, or a
combination of both.
(1) original paper document or secured set of electronic data as the original form (either
paper or via an approved electronically signed form), or
(2) a paper reproduction of a paper document (original or copy), or
(3) an electronic reproduction of a secured set of electronic data (original or copy), or
(4) a printed reproduction of a secured set of electronic data (original or copy), or
(25) as an electronically digitised reproduction copy of the original a paper documentform
(36) as a microfilm or scanned reproduction copy of the original a paper documentform
(4) as a paper form where the paper record is a printed reproduction of an original form
from either (1), (2) or (3) above.
Where IT systems are used to retain documents and data, it should be possible to print a
paper version of the documents and data kept.”
The production and the retention of records may be carried out by different organisations
(e.g. as a result of sub-contracted continuing airworthiness management tasks, refer to
Appendix II to M.A.201(h)(1)). Therefore, both activities should be taken into account.
The records of used aircraft that have already been transferred several times are frequently
copies of copies: relying on copies of the original form only is not flexible enough, and may
lead to an immediate non-compliance for a significant portion of the in-service fleet.
response

NPA 2014-04, page 22/44, AMC M.A.305(e)
It is proposed to modify the title of the paragraph (d) of the AMC M.A.305(e) to read:
“(d) Material/Physical Non-digitised records:
All physical records should […]”
For sake of consistency with the terms used in this paragraph.
response

NPA 2014-04, page 22/44, AMC M.A.305(e)
It is proposed to modify the paragraph (e) of the AMC M.A.305(e) to read:
“(e) Digitised Records:
Digitised records may be created from an original a paper record document (original or
copy) or as a digital electronic original secured set of electronic data. When created from an
original a paper record document:
(1) the creation date of the digitised record should be stored with the digitised record,
(2) it is advisable to create an individual digitised record for each original document, and
technology should ease the future retrieval of the record.”
copies of copies: relying on the original version of the paper document only (excluding first
reproduction, or subsequent copies of such a reproduction) is not flexible enough, and may
response

NPA 2014-04, pages 22-23/44, AMC M.A.305(e)
It is proposed to modify the paragraph (f) of the AMC M.A.305(e) to read:
“(f) Digitised Record Retention:
Digitised records when created from an original a paper record document, or as a digital
electronic original secured set of electronic data, should be stored on a system which is
secured and kept in an environment protected from damage (e.g. fire, flooding, excessive
temperature or accidental erasing). […]
The system used for retention of digitised records must:
1. Ensure the integrity (whatever the record creation form) and accuracy of the record
(when created from an original a paper record document).
2. Ensure that access to the digitised record has safeguards against inadvertent alteration of
the data.
3. Ensure the authenticity of the record (identification of the person who created Provide
assurance that the data and/or has not been modified them after creation).
[…]
Computer backup discs, tapes etc., should be stored in a different location from that
containing the current working discs, tapes, etc., and in a safe environment. Where the
competent authority has approved a system for digitised record keeping satisfying the
above, the original paper record document may be permanently disposed of.”
copies of copies: relying on the original version of the paper document only (excluding first
reproduction, or subsequent copies of such a reproduction) is not flexible enough, and may
Authenticity/Integrity: For sake of clarity.
response

We suggest to add the following sentence to point (c)
Proposal:
‘In the case an IT system is used as a continuing airworthiness record system, the IT system
should have a change log detailing the original entry and the correction made, marked by
date and time and identifying the person making the correction. ‘
Explanation:
To provide clarification and AMC in case an IT system is used for the continuing airworthiness
records system similarto the paper system.
response

AMC M.A.305(e) point (b)
Proposal:
Change ‘logcards’ into ‘in-service history record‘
Explanation:
For consistency with M.A.305(e)3
response

Proposal:
Change AMC M.A.305(e) item (f):
‘Where the competent authority has approved accepted a system for …’
Explanation:
The authority does not approve a digitized record keeping system.
response

- AMC M.A.305 (e) § (b) : to be in line with the wording used in the M.A.305 (e), the text
“other document equivalent in scope and detail” needs to be replaced by “

data equivalent in scope and details".
-AMC M.A.305 (e) § (b) (4) : it could be more appropriate to speak about AD status,
modification status, repair status, maintenance program and to add the deferred
maintenance rectification.
response
AMC M.A. 305(e) point (e)
The regulation should clearly state that digitized records should be legible and all required
details (stamps, notes, drawings) should be clearly identifyable. We have seen gruesome
scans of records that were hardly legible in crucial parts (e.g. AD compliance).
response

Page No: 23
Paragraph No: AMC M.A.305(e)(2)
Comment: The paragraph implies that any EASA Form 1 of components used to perform a
modification or repair are not required to be kept. For components with an airworthiness
limitation, demonstration of its history is required and the Form 1 would provide this. It
should be clear that although not required to be kept by the maintenance organisation,
copies should be kept by the operator.
Justification: The operator should have a complete set of records, this should include any
release documentation for components fitted to the aircraft.
Proposed Text: “AMC M.A.305(e)(2) Aircraft continuing airworthiness record system
(1) EASA Form 1 and the Certificate of Conformity of the components used to perform a
modification/repair are not part of the substantiation data for a modification/repair, which
are retained by the maintenance organisation. Copies should be provided to the operator to
be kept with the aircraft records.”
response

Other paragraphs in M.A. 305 (e) on page 11 and 12 refer to 24 months. This is inconsistent
with the recently adopted approach to keep records in Part M and Part 145 for 36 months in
order to align to record retention period for the ARC inspection.
response

AMC M.A.305(e) Aircraft continuing airworthiness record system (a) The information that
constitutes the aircraft continuing airworthiness records may be entered in an information
technology (IT) system and/or other documents equivalent in scope and detail. IT systems
acceptable for supporting the aircraft continuing airworthiness records should: (1) include
functions so that search of data and production of status, including a printable paper version,
is possible; (2) allow a transfer of the aircraft continuing airworthiness records data from one
system to another using an industry wide/worldwide data format or allow printing
information; (3) contain safeguards which prevent unauthorised personnel from altering
data; and (4) ensure the integrity of the data, including traceability of amendments.
JUSTIFICATION: AMC 305(e) c doesn't specify explicitely that status should be produced in a
paper versions.
Paper version status are assessed and archived during the Airworthiness Review.
From experience some IT system do not produce all informations in a paper versions.
response
comment 261 ❖ comment by: Dassault Aviation

Identification) "
be on control.
response

Dassault-Aviation suggest to add a sentence as :
RFID data are accepted when validity is demonstrated
response
The purpose of this AMC is to describe that the requested record system may be “paper-
driven” or “electronically stored” information. Therefore the (a) paragraph describes the IT
technology and requirements. The (b) reminds the names of paper documents. But the 4
points under (b) are already covered as the “contents” of the “records”. It is not usefull here
to repeat those information.
Delete the 4 points within (b) subparagraphs as follows:
Any logbook/logcard should contain:
(1) Identification of the product, part or component it refers to;
(2) Type, serial number and registration, as appropriate, of the aircraft, engine, propeller,
engine module, or component to which the particular component has been fitted, along with
the reference to the installation and removal;
(3) The date and accumulated total flight time and/or flight cycles and/or landings and/or
calendar time, as appropriate; and
(4) Any AD, modification, repair, maintenance or deferred maintenance tasks applicable.
response

b) weight variant and/or rating as applicable seem to miss.
response

c) form of record keeping: can we consider that we are allowed to destroy the paper form
once it is digitalized? how can we consider a scan printed as original? who endorse the
responsibility to sign them?
for e-signature shall we only consider the EC 93-1999? when transferring aircraft records to
the next owner/operator, shall we accept digitalized data transfert? what about signatories
and DFP signed? does one person can endorse the whole signatures?
response

f) 5) what is the definition of safe environment? is "out of the office area" enough? what
about transfert of electronic record to an organization not approved by the authority on the
e-signatures and electronic/IT system retention/recording?
g) Is there a formal acceptance from the authority for acceptance of recovery and FH/FC
validation?
response

1) Maybe we can be more accurate by telling that CoC or EASA Form 1 of components used
to perform a modification/repair of an equipment is not mandatory? because for example,
we should need CoC or EASA Form 1 for computers, repair of structural part, etc. to accept
and endorse the modification isn't it?
For DOA modifications for example, we should have the EASA form 1 of the
equipments/parts used no?
response

AMC M.A.305(e) - item (c) (1)
“Electronically signed form”: The electronic signature needs to be well defined. Different
states use different processes to define an electronic signature. Will an e-signature by one
state be recognized by another? IATA is offering to continue working with the industry to
define an aviation industry standard that can be used on a global level and ensure
recognition by various agencies.
response

The time spendt on the computer is pointing in the wrong direction. In the -90 you have only
1 window to work in. The time to record fault on the aircraft system was "fast". Now you
need to Log on, accepting, deny in several windows then you have done your work. refilling,
changing bulbs, refastened screws an so on. Today we need somthing that are a lot easier,
this to ensure better feedback about errors found on aircraft and aircraft components.
The problem today is that you go through many windows in the computer program, and its
not a copy of the log book. The danger we see is that all is not necessarily recorded during
technical checks. The job is quicker to perform than it takes you through all the data
windows. We need a text that say somthing about the record systems layout and
functionality, its need to be easy to understand and work in to ensure highest level of safety
and keep in mind a lot of work is done during nightshift.What about Human Factor
response
AMC M.A.305 (e) (b) (3):

This paragraph may require the engine and propeller logbooks to be kept "current" while we
assume date and so on has to be entered on installation and removal only.
response

Comment 1
AMC M.A.305(e) Aircraft continuing airworthiness record system
We believe such IT systems should allow for the "locking down" of data in response to
accidents, serious incidents, and/or other occurrences that may have significant safety
implications.
We recommend adding point (5) as follows:
"(5) ensure data can be "locked down" or otherwise secured from any alterations being
made, in the light of any accident, serious incident and/or occurrence that may have serious
safety implications."
Comment 2
We believe the wording in paragraph (b) (1) may cause confusion between the overlapping
terms referred to. The definition of component includes "parts and appliances" (Regulation
(EC) 2042/2003).
We recommend the following:
(1) Identification of the product or component it refers to;
response

AMC M.A.305(e) Aircraft continuing airworthiness record system
Paragraph (f) contains the word "must"; this is not appropriate for AMC. Paragraph (f) should
read as follows:
(f) Digitised Record Retention:
...
The system used for retention of digitised records should:
... "
response
3. Proposed amendments — 3.2. Draft Decision — 3.2.1. Annex I to Decision 2003/19/RM (AMC p. 23
to Part-M): — Point AMC M.A.305(e)(2)

para. (1) - not clear that substantiating data forms part of the continuing airworthiness
records but EASA Form 1 should be retained by the MRO (if that is the intention of this
paragraph). Suggest the following text:
(1) EASA Form 1 and the Certificate of Conformity of the components used to perform a
modification/repair are not part of the substantiation data for a modification/repair and
should be retained by the maintenance organisation.
response

Clarify the meaning of this paragraph regarding EASA form1 is not part of subtantiating data
?
Please illustrate your expectation regarding this paragraph related to EASA Form1 need.
response

AMC M.A. 305(e)(2) point (1)
The intent of this AMC is not clear due to punctuation and alternate meanings for
‘component’ (which may mean ‘materials’ in this case). Clarification is required whether this
refers to substantiation of compliance with the design requirement, or substantiation of the
quality processes used to produce the material used in a repair or modification. If the
reference is to substantiation of compliance with the design requirement then the
owner/operator would require appropriate ‘substantiation data’ but if the intent is
substantiation of quality procedures used in the production of the material used by the
maintenance organisation then the maintenance organisation would need to retain
appropriate substantiation. An alternative sentence may be:
‘EASA Form 1 and the Certificate of Conformity of the components and/or materials used to
perform a modification/repair are retained by the maintenance organisation and are not part
of the substantiation data for a modification/repair required to be retained by the owner or
operator’.
response

NPA 2014-04, page 23/44, AMC M.A.305(e)(2)

Could the Agency clarify in the following sentence what is retained by the maintenance
organisation amongst the EASA Form 1, the Certificate of Conformity, and the substantiation
data?
“(1) EASA Form 1 and the Certificate of Conformity of the components used to perform a
are retained by the maintenance organisation.”
Should it be modified to read the following?
“(1) EASA Form 1 and the Certificate of Conformity of the components used to perform a
modification/repair are not part of the substantiation data for a modification/repair., which
These [EASA Form 1/Certificate of Conformity/substantiation data] are retained by the
maintenance organisation.”
For sake of understanding. It is not clear what the Regulator expects from the persons or
organisations responsible for the maintenance and/or the aircraft continuing airworthiness.
response

NPA 2014-04, page 23/44, AMC M.A.305(e)(2)
Could the Agency clarify what an ‘interim assessment’ means in the following sentence?
“(2) In the case of an AD with several steps or with interim assessments during its
application, these intermediate steps are part of the detailed maintenance records.”
response

AMC M.A.305 (e) (2) § (1) and AMC M.A.305 (e) (3) § (1) : based on this text, it seems
important to clarify that the record related to the components needs to be kept, in the
general record for components, to ensure traceability. In the case of the “AMC M.A.305(e)
(3) § (1)”, it is little confused with the other article “GM M.A.305 (e) (3)”.
response

AMC M.A.305(e)(2)(1)
Comment: change text into: “….(1) include functions so that search of data and generating
production of a status-overview is possible;…”
response

AMC M.A.305(e)(1)(1)
Comment:
The proposed text states that:
“EASA Form 1 and the Certificate of Conformity of the components used to perform a
are retained by the maintenance organisation.” This could suggest that the substantiation
data for a modification/repair, instead of the EASA Form 1 and the Certificate of Conformity,
are retained by the maintenance organization. However, the substantiation data for a
modification/repair are part of an EASA Part 21 design, and should be retained by the Design
Approval Holder (DAH).
It is proposed to change the text to:
“EASA Form 1 and the Certificate of Conformity of the components used to perform a
modification/repair are not part of the substantiation data for a modification/repair. EASA
Form 1 and the Certificate of Conformity of the components are retained by the
maintenance organisation.”
response
p. 23
to Part-M): — Point AMC M.A.305(e)(3)

Please illustrate your expectation regarding this paragraph related to EASA Form1 need.
response
page 23
AMC M.A.305(e)(3)
(2) Conservative methods...
Proposal:
Please replace "conservative" by "traditional" or "purpose-tailored..."
Rationale:
"conservative" is a political term, not a technical one.
We propose "Any suitably safe method to manage missing historical periods is acceptable..."
response

GM M.A.305(e)(3):
The caveat ‘unless this is the means to fulfil another requirement quoted in M.A.305, (e.g.
maintenance programme task compliance)’ is unclear since condition monitoring
components may remain in service without preventive maintenance until failure. We
propose that the Agency revise this sentence as follows:
‘The EASA Form 1 or equivalent, and associated detailed maintenance records, is are not
requested to be kept for ‘condition monitoring’ components unless this is the means to fulfil
another requirement quoted in M.A.305, (e.g. maintenance programme task compliance
demonstration of AD compliance).
When condition monitoring components are subject to reliability monitoring further
guidance material is beneficial. GM M.A. 305(e)(3) could therefore be elaborated as follows:
‘It may be necessary to record the maintenance status for condition monitoring components
which are monitored under a reliability/health monitoring programme as applicable in
accordance with the aircraft maintenance programme. A fitted component list of
components monitored for reliability by the person or organisation responsible for the
aircraft continuing airworthiness may be kept in order to record the installed component part
and serial number, time of component installation and applicable monitored criteria.’
response

NPA 2014-04, page 23/44, AMC M.A.305(e)(3)
It is proposed to modify the AMC M.A.305(e)(3) to read:

“(1) An EASA Form 1 or equivalent and detailed maintenance records are not meant
requested to be kept to support every installation/removal shown in the in-service history
records.”
The wording “are not requested to be kept to support” has been found more explicit than
“are not meant to support”. The proposal is based on GM M.A.305(e)(3).
response

NPA 2014-04, page 23/44, AMC M.A.305(e)(3)
Could the Agency clarify who is responsible for deciding what is conservative and what is not,
as a result of the following paragraph?
“(2) Conservative methods to manage missing historical periods are acceptable to establish
the current status of the life limited part. In case of use of a conservative method, the
supporting documents should be endorsed. Recommendations from the DAH on the
procedures to record or reconstruct the in-service history should be considered.”
Should it read the following?
“(2) Conservative methods to manage missing historical periods that are approved under
the Annex (Part-21) to Regulation (EU) No 748/2012 are acceptable to establish the current
status of the life limited part. […]. Additional Rrecommendations from the DAH on the
procedures to record or reconstruct the in-service history should be considered.”
Could the Agency clarify who is responsible for endorsing the supporting documents and
what are the supporting documents?
Experience shows that what is conservative and what is not varies from one
person/organisation to another. Further, a person or organisation responsible for the aircraft
continuing airworthiness may in good faith consider that a given method is conservative
whereas the pertinent Type Certificate Holder (i.e. a very particular DAH) can demonstrate
the opposite.
Responsibilities have to be clarified with regards to which documents have to be endorsed
and by whom.
response

We suggest to add AMC No. 2 to M.A.305(e)
Proposal:
‘In case of escalations and deviations to the maintenance program, all supporting
information and maintenance records of the reviews required by M.A.302(d)(iii) should be
retained for the period for at least 36 months after the escalation/deviation has been
approved’.
Explanation:
Currently, there is no rule of retaining the records of the reviews. To ensure that a
verification can be performed for the validity of the escalation, AMC is created to explain
that to comply with the rule, the records of the reviews must be retained.
response

AMC M.A.305 (e) (3) (1): Amendment should be made:
If an EASA Form 1 is used as supporting document, it might be the EASA Form 1 of the Next
Higher Assy and is not necessarily the individual EASA Form 1 of the component.
response

AMC M.A.305 (e) (3) (1): Amendment should be made: If an EASA Form 1 is used as
supporting document, it might be the EASA Form 1 of the Next Higher Assy and is not
necessarily the individual EASA Form 1 of the component.
response

1) We should be carreful on where is the limit of an EASA Form 1? as understood here, no
need of EASA form 1 for an engine or landing gears... we need at least the last one isn't it?
response
p. 24
to Part-M): — Point GM M.A.305(e)(3)

NPA 2014-04, page 24/44, GM M.A.305(e)(3)
Could the Agency clarify why EASA Form 1 for ‘condition monitoring’ components should be
kept when they are the means to fulfil a requirement quoted in the point M.A.305 other
than in the paragraph (e)(3)*? (Maybe with some examples other than the compliance with
the aircraft maintenance programme tasks)
* i.e. the retention of records for life limited parts and time controlled components.
It is proposed to amend the GM M.A.305(e)(3) to read:
“The EASA Form 1 or equivalent, and associated detailed maintenance records is are not
requested to be kept for ‘condition monitoring’ components unless this is the means to fulfil
another requirement quoted in M.A.305, (e.g. maintenance programme task compliance).
However, it may be necessary to keep some detail maintenance records for those
components monitored under a reliability/health monitoring programme, if applicable
within the frame of the aircraft maintenance programme.
For components that are not subject to any of the primary maintenance processes
described in the GM M.A.305(d)(2) (i.e. Hard Time, On-Condition, Condition Monitoring),
the EASA Form 1 or equivalent, and associated detailed maintenance records are not
requested to be kept as well.”
If the explanation of the exception is not clear and simple, it may be confusing to refer to
‘condition monitoring’ components in a GM related to a paragraph dedicated to life limited
parts and time controlled components:
By definition (ref. to GM M.A.305(d)(2)), a ‘condition monitoring’ component is permitted to
remain in service without preventive maintenance until its functional failure (‘fly to failure’):
it cannot be a life limited part or a time controlled component. Consequently, the point
M.A.305(e)(3) seems to be not applicable.
In addition, the example chosen (i.e. aircraft maintenance programme task compliance) to
illustrate the exception is ambiguous: this kind of components is subject to unscheduled
maintenance only, mainly for their replacement. For much more critical parts, the paragraph
(1) of the AMC M.A.305(e)(3) confirms that an EASA Form 1 and detailed maintenance
records are not meant to support every installation/removal of the life limited part shown in
the in-service history records. So from the standpoint of the aircraft continuing
airworthiness, what is the added value of keeping the EASA Form 1 for a ‘condition
monitoring’ component? This deserves an explanation.
With regard to the detailed maintenance records related to ‘condition monitoring’
components, it may be necessary to keep some of them in order to fulfil a requirement of a
reliability/health monitoring programme following the instructions of the Appendix I to AMC
M.A.302 and AMC M.B.301(b).
The case of components not subject to any primary maintenance process is also explicitly
addressed.
response
The regulation should clearly state that all detailed maintenance records are needed to
demonstrate airworthiness compliance, the maintenance programme task compliance is
maybe not a very good example, AD compliance would be a better one.
response

Page No: 24
Paragraph No: GM M.A.305(e)3
Comment: The word “requested” should be replaced with ‘required’.
Justification: Clarity.
Proposed Text: ”The EASA Form 1 or equivalent is not required …”
response

GM M.A.305(e)(3) Aircraft continuing airworthiness record system
We believe this paragraph contains a number of typographical errors, and, by definition,
condition monitored components do NOT have scheduled maintenance tasks associated with
them, otherwise they would be "Hard Time" or "On Condition". Hence this paragraph should
read as follows:
The EASA Form 1 or equivalent is not required to be kept for ‘condition monitored’
components unless this is the means to fulfil another requirement quoted in M.A.305, (e.g.
Airworthiness Directive compliance).
response
p. 24
to Part-M): — Point AMC M.A.305(f)

NPA 2014-04, page 24/44, AMC M.A.305(f)

It is proposed to amend the AMC M.A.305(f)* to read:
“When an owner/operator the person or organisation responsible for the aircraft
continuing airworthiness arranges in accordance with the Appendix II to M.A.201(h)(1) for
the relevant maintenance a subcontracted organisation to retain copies of the continuing
airworthiness records on his/her/its behalf, the owner/operator person or organisation
responsible for the aircraft continuing airworthiness will continue to be responsible for the
retention of records. If they cease to be the owner/operator of the aircraft, they also
remain responsible for transferring the records to the new owner/operator of the aircraft.”
* Concurrent amendment: AMC M.A.307(a).
A maintenance organisation is not the only possible sub-contracted organisation.
The point M.A.305(f) addresses the control of aircraft continuing airworthiness records in
accordance with M.A.305 (i.e. production and retention). It does not control the transfer of
aircraft continuing airworthiness records like the point M.A.307 does.
So, the acceptable means of compliance linked to the responsibility for keeping records
should be addressed in the AMC M.A.305(f) while those linked to the responsibility for
transferring records should be addressed in the AMC M.A.307(a).
response

Point M.A.307
AMC M.A.307
It is proposed to amend the paragraph (a) of point M.A.307 to read:
“(a) The owner or operator person or organisation responsible for the aircraft continuing
airworthiness shall ensure when an aircraft, an engine, a propeller, or a component is
permanently transferred from one owner or operator to another that the M.A.305
continuing airworthiness records necessary to demonstrate compliance with point M.A.305
and, if applicable, M.A.306 operator’s technical log are also transferred.”
It is proposed to amend the AMC M.A.307(a)* to read:
“Where an owner/operator terminates his operation, all retained continuing airworthiness
records should be passed on to the new owner/operator or stored. When the person or
organisation responsible for the aircraft continuing airworthiness arranges for the relevant
maintenance organisation to retain (in accordance with M.A.305) copies of the continuing
airworthiness records on his/her/its behalf, the person or organisation responsible for the
aircraft continuing airworthiness will continue to be responsible for transferring the
records to the new owner/operator of the aircraft.
[…].”
* Concurrent amendment: AMC M.A.305(f).
At the aircraft level, the transfer of continuing airworthiness records is appropriately
controlled by the current version of point M.A.307.
The rework of point M.A.305, and in particular the new paragraph (e)3., rightly sheds light on
components and makes them more visible than before. This paragraph demonstrates that
some continuing airworthiness records rather relate to engines/engine modules, propellers,
and components than to the aircraft itself. When an engine/engine module, a propeller or a
component is transferred (e.g. standard exchanges) these records should also be transferred.
As a consequence, the point M.A.307 needs to be amended to reflect this reality.
The term ‘the person or organisation responsible for the aircraft continuing airworthiness’ is
preferred to ‘owner/operator’ to explicitly cover the case of a CAMO arranging for the
relevant maintenance organisation to retain copies of the continuing airworthiness records
on its behalf.
response

AMC M.A.305(f) Aircraft continuing airworthiness record system
This paragraph is easily applied in relation to aircraft used for CAT operations, whereby the
operator and the managing CAMO are one and the same organisation.
However for non-CAT aircraft the owner/operator and the CAMO managing the continuing
airworthiness may be separate organisations and the proposed wording does not adequately
cater for this scenario.
We suggest the following wording would assist with the principle in each situation:
When an owner/operator or CAMO arranges for the relevant maintenance organisation to
retain copies of the continuing airworthiness records on its behalf, the owner/operator or
that CAMO will continue to be responsible for the retention of records. If they cease to be
the owner/operator or CAMO of the aircraft, then the owner/operator is responsible for
transferring the records to the new owner/operator or CAMO of the aircraft.
response
3. Proposed amendments — 3.2. Draft Decision — 3.2.1. Annex I to Decision 2003/19/RM (AMC p. 24
to Part-M): — Point AMC M.A.305(h)6

Although not in the original EASA proposal:
We suggest to add a new AMC No. 2 to M.A.307(a)
“In case of a permanent transfer of a component to another owner/operator, the previous
owner/operator should ensure that all relevant documents (such as but not limited to the in-
service history card, status of AD’s, status of modifications and repairs, all relevant
Authorised Release Certificates, substantiation of non-generic modifications and repairs)
should be transferred to the new owner/operator. “
Explanation:
To provide clarification and acceptable means of compliance
response
p. 25
to Part-M): — Point AMC M.A.501(b)

NPA 2014-04, page 25/44, AMC M.A.501(b)
Point M.A.501
Point 145.A.42
AMC 145.A.42(b)
It is proposed to amend the point M.A.501 to read:
“[…]
(b) Prior to installation of a component on an aircraft the person or approved maintenance
organisation shall ensure that the particular component is eligible to be fitted when different
modification and/or airworthiness directive configurations may be applicable. […]”
It is proposed to amend the AMC M.A.501(b) to read:
“(3) The person referred to under M.A.801 or the M.A. Subpart F or Part-145 approved
maintenance organisation should be satisfied ensure that the component in question meets
the approved data/standard,. Care should be taken in ensuring prior to installation that
compliance with the approved configuration and maintenance data/standard is
demonstrated such as the required design and modification standards. This may be
accomplished by, amongst others:

– reference to the (S)TCDAH holder or manufacturer’s parts catalogue or other approved
data (i.e.e.g. Service Bulletins), and
– checking the pertinent data described in M.A.305(c) and (d).
Care should also be taken in ensuring compliance with applicable AD and the status of any
service life-limited life limited parts and time controlled components fitted to the aircraft
component.”
It is proposed to amend point 145.A.42 to read:
“(b) Prior to installation of a component, the organisation shall ensure that the particular
component is eligible to be fitted when different modification and/or airworthiness
directive standards may be applicable.”
It is proposed to amend the AMC 145.A.42(b) to read:
“1. The EASA Form 1 or equivalent identifies the status of an aircraft component. Block 12
‘Remarks’ on the EASA Form 1 in some cases contains vital airworthiness related information
which may need appropriate and necessary actions.
2. The receiving organisation should be satisfied that the component in question is in
satisfactory condition and has been appropriately released to service.
3. In addition, tThe organisation should ensure that the component in question meets the
approved data/standard,. Care should be taken in ensuring prior to installation that
compliance with the approved configuration and maintenance data/standard is
demonstrated such as the required design and modification standards. This may be
accomplished by, amongst others:
– reference to the DAH holder or manufacturer’s parts catalogue or other approved data
(i.e.e.g. Service Bulletins, the Airworthiness Limitations Section for Critical Design
Configuration Control Limitations), and
– checking the pertinent data described in M.A.305(c) and (d).
Care should also be taken in ensuring compliance with applicable airworthiness directives,
the status of any life-limited parts fitted to the aircraft component as well as Critical Design
Configuration Control Limitations.”
A recent experience has shown that an operator/a maintenance organisation may
unintentionally install a component that is not eligible for the aircraft, although compliance
with the points M.A.501(b)/145.A.42(b) is demonstrated:
These points give the impression to focus on the different modification and/or airworthiness
directive standards/configurations (e.g. with the help of the IPC). Unintentional deviations
(often referred to as concessions, non-conformances, divergences, repairs, technical
adaptations, technical variations, etc…) may include restrictions on the affected component’s
eligibility for fitment to aircraft.

The rework of point M.A.305, and in particular the new paragraph (e)3., rightly sheds light on
components and makes them more visible than before. This paragraph demonstrates that
some continuing airworthiness records rather relate to engines/engine modules, propellers,
and components than to the aircraft itself: e.g. engine life limited parts status. When an
engine/engine module, a propeller or a component is transferred (e.g. standard exchanges)
these records should also be transferred (refer to comment on M.A.307 amendment): these
records will be an essential contributor to determine if the component may be fitted to the
aircraft or not.
As a consequence, the points M.A.501/145.A.42 need to be amended to reflect this reality.
The Key Risk Elements A.1, A.2, A.3, B.3, C.1, C.2, C.3, C.4 have been a source to identify
possible gaps.
response

The AMC states: “The EASA Form 1 or equivalent identifies the [airworthiness] status of an
aircraft component. Block 12 ‘Remarks’on the EASA Form 1 in some cases contains vital
airworthiness related information which may need appropriate and necessary actions. ….”
That is not always correct: after maintenance the EASA Form 1 is used to release the work
carried out, it is not a statement that the component is airworthy.
Proposal:
Change the text into:
The EASA Form 1 or equivalent in-service history record identifies the airworthiness status of
an aircraft component. Block 12 ‘Remarks’on the EASA Form 1 after maintenance in some
cases contains vital airworthiness related information which may need appropriate and
necessary actions.
Explanation:
To ensure that during the receiving inspection, the in-service history record is the prime
document to be reviewed.
A widely adopted practice in the industry is that during the receiving inspection, only the
Authorised Release Form is checked and not the ‘maintenance history card’. This practice
stems from the practice that operators sent out a particular components for maintenance
work and received the same component. In such case, it was sufficient only to verify that the
maintenance ordered was indeed performed, hence by checking the Authorised Release
Certificate.
However, components are more and more interchanged with another component (a.k.a.
exchange) from pooling contracts (total care packages) where the ownership changes.
During the receiving inspection of such components, it is not sufficient to only review the last
Authorised Release Certificate, but to review the full history of the component, including all
applicable AD’s, performed modifications and repairs (the latter with possible restricted
certified airworthiness limitations and/or additional inspection). Thus the emphasis during
the receiving inspection should be changed. An amendment to AMC 145.A.42(b) and AMC
M.A.501(b) is proposed.
response
p. 25
to Part-M): — Point AMC M.A.504(c)

NPA 2014-04, page 25/44, AMC M.A.504(c)
It is proposed to amend the AMC M.A.504(c) to read:
“1. The following types of components should typically be classified as unsalvageable:
(…)
(d) certified life-limited parts life limited parts that have reached or exceeded their certified
life limits specified mandatory life limitation specified in the maintenance schedule of the
aircraft maintenance programme, or have missing or incomplete records;
For consistency of terms used.
response
p. 25
to Part-M): — Point AMC M.A.504(d)(2)

NPA 2014-04, page 25/44, AMC M.A.504(d)(2)
Could the Agency remind the reference of the requirement imposing on manufacturers
producing approved aircraft components to maintain records of serial numbers for ‘retired’
life limited parts?
Could the Agency confirm that the deletion of reference to ‘critical’ parts/components in the
core text of the Part-M and/or its AMC will not create any hazards?
The reference to the requirement in the Part-21 and/or Certification Specifications would
ensure consistency of requirements for initial and continuing airworthiness.
The deletion of reference to ‘critical’ parts/components may have a direct impact on
rotorcraft. For example, CS 27.602 and CS 29.602 define a critical part as a part, the failure of
which could have a catastrophic effect upon the rotorcraft, and for which critical
characteristics have been identified which must be controlled to ensure the required level of
integrity. If the type design includes critical parts, a critical parts list shall be established.
Procedures shall be established to define the critical design characteristics, identify
processes that affect those characteristics, and identify the design change and process
change controls necessary for showing compliance with the quality assurance requirements
of Part-21. It has not been possible to identify in these CS a requirement imposing the
systematic assignment of a life limitation to rotorcraft critical parts.
Are requirements for initial and continuing airworthiness consistent? Is such a list of critical
parts required for aeroplanes?
Note: For engines, the CS-E imposes a holistic approach:
CS-E 515 requires an engineering plan, a manufacturing plan and a service management.
These three plans define a closed-loop system which links the assumptions made in the
engineering plan to how the part is manufactured and maintained in service. The integrity of
engine critical parts is established by:
An engineering plan, the execution of which establishes and maintains that some parameters
for design are sufficiently well known or predictable to allow each engine critical part to be
withdrawn from service at or before an approved life limitation (before hazardous failure
effects can occur).
A manufacturing plan which identifies the specific manufacturing constraints necessary to
consistently produce engine critical parts with the attributes required by the engineering
plan.
A service management plan which defines in-service processes for maintenance of engine
critical parts which will maintain attributes consistent with those required by the engineering
plan.
These processes become part of the Instructions for Continued Airworthiness used by the
person or organisation responsible for the aircraft continuing airworthiness to develop an
aircraft maintenance programme.
response
p. 25
to Part-M): — Point AMC M.A.613(a)
comment 2 comment by: Arturas Vegys

This point indicates that "Inspected" should be stated in block 11 of EASA Form 1.
But Appendix II to Part M describes the permissible entries for block 11, stating that only
four entries are available for use: Overhauled, Repaired, Inspected/Tested, Modified.
This leads to misunderstanding from the issuer of EASA Form 1 whether to use "Inspected"
or "Inspected/tested".
response

NPA 2014-04, page 25/44, AMC M.A.613(a)
NPA 2014-04, page 29/44, AMC No 2 to 145.A.50(d)
It would be advisable to review both of these AMC in order to direct the reader to the point
M.A.305. Meanwhile, it is proposed to amend the AMC M.A.613(a) to read:
“[…]
2.4. An EASA Form 1 issued in accordance with this paragraph 2 should be issued by signing
in block 14b and stating ‘Inspected’ in block 11. In addition, block 12 should specify:
(…)
2.4.4. detail of life used for service life-limited life limited parts and time controlled
components being any combination of life since newfatigue, life accumulated by the time
controlled components since the last accomplishment of scheduled maintenance specified
in the aircraft maintenance programme overhaul or storage life;
(…)
(g) The total in-service life accumulated in flight hours and/or flight cycles and/or landings
and/or any other applicable parameter should be established flight hours/cycles/landings
as applicable of any service life-limited for life limited parts and time controlled
components, including together with the life accumulated by the time controlled
components since the last accomplishment of scheduled maintenance task(s) specified in
the aircraft maintenance programme time since overhaul should be established.
[…]”
It is proposed to amend the AMC No 2 to 145.A.50(d) to read:
“[…]
2. In the case of the issue of EASA Form 1 for components in storage before Part-145 and
Part-21 became effective and not released on an EASA Form 1 or equivalent in accordance
with 145.A.42(a) or removed serviceable from a serviceable aircraft or an aircraft which has
been withdrawn from service the following applies:
(…)
2.4.4. Detail of life used for service life-limited parts life limited parts and time controlled
controlled components since the last accomplishment of scheduled maintenance task(s)
specified in the aircraft maintenance programme overhaul or storage life.
(…)
2.6.1 Serviceable aircraft components removed from a Member State registered aircraft may
be issued with an EASA Form 1 by an appropriately rated organisation subject to compliance
with this subparagraph.
(…)
as applicable of any service life-limited parts for life limited parts and time controlled
(…)”
These AMC contain details under the responsibility of the person or organisation managing
the aircraft continuing airworthiness: e.g. in the sub-paragraphs 2.4.3. and 2.4.4., 2.6.1.
items (d), (f), (g) and (h). For such details, an approach like the one proposed in the
paragraph (b) of points M.A.614 and 145.A.55 would limit duplications and needs for revision
when the point M.A.305 is amended. In other words, the maintenance organisation should
be directed to the person or organisation responsible for the aircraft continuing
airworthiness in order to obtain, before issuing the EASA Form 1, the component records
necessary to demonstrate compliance with M.A.305.
M.A.305 wordings have been used to modify these AMC.
Fatigue is not the only damage source generating life limitations (for example, refer to CS-25,
Appendix H, paragraph H25.4, sub-paragraph (a)(1) for fatigue & (a)(3) for EWIS). It is
preferable to refer to ‘life since new’.
The required periodic maintenance task(s) from the maintenance schedule of the aircraft
maintenance programme specific to the time controlled components is/are not
systematically overhauls. Therefore, it is preferable to refer to the ‘life accumulated by the
time controlled components since the last accomplishment of scheduled maintenance
specified in the aircraft maintenance programme’.
response

AMC No2 145.A.50(d) and AMC M.A.613(a) please use the term ‘maintenance history record’
in paragraphs 2.4.5 and 2.6.1(e).
Proposal:
Replace ‘maintenance history record’ with ‘in-service history record’
Explanation:
For consistency with M.A.305
response

AMC M.A.613(a)
Comment : also cross out “service” in the sentence at 2.6 (g):
“.. (g) The flight hours/cycles/landings as applicable of any service life-limited life
limited parts and time controlled components including time since overhaul should be
established….”
response
p. 26
to Part-M): — Point AMC M.A.710(a)

NPA 2014-04, page 26/44, AMC M.A.710(a)
It is proposed to amend the AMC M.A.710(a) to read:
“(1) A full documented review is a check of at least the following categories of documents:
- status list of service life-limited component life limited parts and time controlled
components,”
For consistency with the terms used in point M.A.305.
response
p. 26
to Part-M): — Points AMC M.A.901(d) and (g)

NPA 2014-04, page 26/44, AMC M.A.901(d) and (g)
It is proposed to amend the AMC M.A.901(d) and (g) to read:
“(g) Statement
(…)
- component service life mandatory airworthiness limitations for components, and;”
For consistency with the terms used in point M.A.305.
response

AMC M.A.901 (d) and (g) : it could be useful to change the wording to be in line with the
“new” wording in the proposed regulation in term of “life limited parts” and “time
controlled components” to harmonize the wording through whole regulation and
AMC/GM. We can suggest for this AMC a wording like : “approved limits for life limited
parts and time controlled components”.
response
p. 26
to Part-M): — Point 2.11 of Appendix XI to AMC M.A.708(c)

Point M.A.708(b)

It is proposed to modify the point M.A.708 to read:
“(b) For every aircraft managed, the approved continuing airworthiness management
organisation shall:
[…]
8. coordinate scheduled maintenance, the application of airworthiness directives, the
replacement of service life limited parts, and component inspectionmaintenance to ensure
the work is carried out properly,
[...]”
Amendment of this point should be contemplated (holistic approach for consistency).
response
p. 27-28
to Part-M): — Appendix III to GM1 M.B.303(b)

Supporting information, para (b). "components for which failure resistance can reduce and
drop below a defined level: Inspections are scheduled to detect potential failures. Reference
is made to ‘On-condition’ components: They are called such because components, which are
inspected, are left in service (no further maintenance action taken) on the condition that
they continue to meet specified performance standards." These are not "time controlled
components" as defined. Furthermore, the terms "On Condition" and "Condition
Monitoring" have been transposed, also in notes to this paragraph. (cf. GM
M.A.305(d)(2)(c)(2), p.21)
response

NPA 2014-04, pages 27-28/44, Appendix III to GM M.B.303(b)
It is proposed to amend the Appendix III to GM M.B.303(b) to read:
“[…]
Supporting Information
[…]
Components affected by scheduled maintenance are of two types:

Life-limited components are of two types:
- components subject to a certified life limit;
- components subject to a service life limit.
a) Components with a certified life-limit mandatory life limitation must be permanently
removed from service when, or before, their operating limitation is exceeded. The life
limitation is controlled at the component level (in opposition to aircraft level).
[…]
Typical inspection items
[…]
4. Check current status of life limited parts life-limited components. This status can be
requested upon each transfer throughout the operating life of the part:
a. It must identify Tthe life limitation, the component’s total accumulated life, and the life
remaining before the component’s life limitation is reached (indicating Hours, Cycles,
Landings, Calendar time, as necessary).
b. If relevant for the determination of the remaining life,It must be substantiated by in-
service history records a full installation history indicating the number of hours, cycles or
calendar time relevant to each installation on these different types of aircraft/engine.”
For consistency with the terms and definitions used in point M.A.305/AMC/GM.
response

Appendix III to GM1 M.B.303(b) : in the box entitle “supporting information”, it could be
useful to replace “a) Components with a certified life-limit must be permanently removed
from service when, or before…” by “a) Components which are ‘life limited parts” must be
permanently removed from service when, or before…” to harmonize the wording used in this
NPA. Same remark for the text in the box entitled “Typical inspection items”, “6. Check that
life-limited and time controlled components are correctly marked during a physical survey.”
could be improved by “6. Check that life-limited parts and time
response

Appendix III to GM1 M.B.303(b)
 C.2 Component control, In the right column “Typical inspection items”, Item 6:
 We propose a change for consequence use of “life limited part”

 NPA: “Check that life-limited and time controlled components are correctly marked
during a physical survey.”
 To: Check that life-limited part and time controlled components are correctly marked
during a physical survey.
response

App III to GM1 M.B.303 (b) 'Key Risk Elements' C.2 Component Control Supporting
information (a):
"[...] certified life-limit [...]" -> "certified" should be deleted
App III to GM1 M.B.303 (b) 'Key Risk Elements' C.2 Component Control Typical inspection
items 4. b.:
"If relevant for the determination of the remaining life, a full installation history incdicating
the number of hours, cycles or calendar time relevant to each isntallation on these different
types of aircraft/engine."
-> This sentence might indicate that a "full installation history indicating [...]" is only needed
"if relevant" what is in contradiction to GM M.A.305 (9) (iii).
response

App III to GM1 M.B.303 (b) 'Key Risk Elements' C.2
Component Control Supporting information (a): "[...] certified life-limit [...]" -> "certified"
should be deleted
App III to GM1 M.B.303 (b) 'Key Risk Elements' C.2
Component Control Typical inspection items 4. b.:
"If relevant for the determination of the remaining life, a full installation history indicating
the number of hours, cycles or calendar time relevant to each installation on these different
types of aircraft/engine."
-> This sentence might indicate that a "full installation history indicating [...]" is only needed
"if relevant" what is in contradiction to GM M.A.305 (9) (iii).
response
Appendix III to GM1 M.B.303(b) ‘KEY RISK ELEMENTS’

Typical inspection items
4.b. 2nd line
The word “landings” needs to be added after cycles.
Comment: It is unclear why both words “cycles” and “landings” are used separately. They
mean the same; therefore, it is proposed to use: “cycles/landings” vs. “cycles” and “landings”
throughout the whole NPA.
response
3. Proposed amendments — 3.2. Draft Decision — 3.2.2. Annex II to Decision 2003/19/RM (AMC
p. 29
to Part-145) — AMC No 2 to 145.A.50(d)

NPA 2014-04, page 25/44, AMC M.A.613(a)
NPA 2014-04, page 29/44, AMC No 2 to 145.A.50(d)
It would be advisable to review both of these AMC in order to direct the reader to the point
M.A.305. Meanwhile, it is proposed to amend the AMC M.A.613(a) to read:
“[…]
2.4. An EASA Form 1 issued in accordance with this paragraph 2 should be issued by signing
in block 14b and stating ‘Inspected’ in block 11. In addition, block 12 should specify:
(…)
2.4.4. detail of life used for service life-limited life limited parts and time controlled
controlled components since the last accomplishment of scheduled maintenance specified
in the aircraft maintenance programme overhaul or storage life;
(…)
as applicable of any service life-limited for life limited parts and time controlled
[…]”
It is proposed to amend the AMC No 2 to 145.A.50(d) to read:
“[…]
2. In the case of the issue of EASA Form 1 for components in storage before Part-145 and
Part-21 became effective and not released on an EASA Form 1 or equivalent in accordance
with 145.A.42(a) or removed serviceable from a serviceable aircraft or an aircraft which has
been withdrawn from service the following applies:
(…)
2.4.4. Detail of life used for service life-limited parts life limited parts and time controlled
controlled components since the last accomplishment of scheduled maintenance task(s)
specified in the aircraft maintenance programme overhaul or storage life.
(…)
2.6.1 Serviceable aircraft components removed from a Member State registered aircraft may
be issued with an EASA Form 1 by an appropriately rated organisation subject to compliance
with this subparagraph.
(…)
as applicable of any service life-limited parts for life limited parts and time controlled
(…)”
These AMC contain details under the responsibility of the person or organisation managing
the aircraft continuing airworthiness: e.g. in the sub-paragraphs 2.4.3. and 2.4.4., 2.6.1.
items (d), (f), (g) and (h). For such details, an approach like the one proposed in the
paragraph (b) of points M.A.614 and 145.A.55 would limit duplications and needs for revision
when the point M.A.305 is amended. In other words, the maintenance organisation should
be directed to the person or organisation responsible for the aircraft continuing
airworthiness in order to obtain, before issuing the EASA Form 1, the component records
necessary to demonstrate compliance with M.A.305.
M.A.305 wordings have been used to modify these AMC.
Fatigue is not the only damage source generating life limitations (for example, refer to CS-25,
Appendix H, paragraph H25.4, sub-paragraph (a)(1) for fatigue & (a)(3) for EWIS). It is
preferable to refer to ‘life since new’.
The required periodic maintenance task(s) from the maintenance schedule of the aircraft
maintenance programme specific to the time controlled components is/are not

systematically overhauls. Therefore, it is preferable to refer to the ‘life accumulated by the
time controlled components since the last accomplishment of scheduled maintenance
specified in the aircraft maintenance programme’.
response

AMC No2 145.A.50(d) and AMC M.A.613(a) please use the term ‘maintenance history record’
in paragraphs 2.4.5 and 2.6.1(e).
Proposal:
Replace ‘maintenance history record’ with ‘in-service history record’
Explanation:
For consistency with M.A.305
response

Although not in the EASA proposal we suggest a new AMC 145.A.42(b) Acceptance of
components stating: “The EASA Form 1 or equivalent identifies the [airworthiness] status of
an aircraft component. Block 12 ‘Remarks’on the EASA Form 1 in some cases contains vital
airworthiness related information which may need appropriate and necessary actions. ….”
That is not always correct: after maintenance the EASA Form 1 is used to release the work
carried out, it is not a statement that the component is airworthy.
Proposal:
Change the text into:
The EASA Form 1 or equivalent in-service history record identifies the airworthiness status of
an aircraft component. Block 12 ‘Remarks’on the EASA Form 1 after maintenance in some
cases contains vital airworthiness related information which may need appropriate and
necessary actions.
Explanation:
To ensure that during the receiving inspection, the in-service history record is the prime
document to be reviewed.
A widely adopted practice in the industry is that during the receiving inspection, only the
Authorised Release Form is checked and not the ‘maintenance history card’. This practice
stems from the practice that operators sent out a particular components for maintenance
work and received the same component. In such case, it was sufficient only to verify that the
maintenance ordered was indeed performed, hence by checking the Authorised Release
Certificate.
However, components are more and more interchanged with another component (a.k.a.
exchange) from pooling contracts (total care packages) where the ownership changes.
During the receiving inspection of such components, it is not sufficient to only review the last
Authorised Release Certificate, but to review the full history of the component, including all
applicable AD’s, performed modifications and repairs (the latter with possible restricted
certified airworthiness limitations and/or additional inspection). Thus the emphasis during
the receiving inspection should be changed. An amendment to AMC 145.A.42(b) and AMC
M.A.501(b) is proposed.
response
3. Proposed amendments — 3.2. Draft Decision — 3.2.2. Annex II to Decision 2003/19/RM (AMC
p. 29
to Part-145) — Point GM 145.A.55 (a)

NPA 2014-04, page 29/44, GM 145.A.55(a)
Could the Agency clarify the meaning of ‘significant aircraft components’ in the following
sentence:
“The aircraft record should contain basic details of all serialised aircraft components and all
other significant aircraft components installed during the maintenance performed, to ensure
traceability to such installed aircraft component documentation and associated maintenance
data as specified in 145.A.45.”
Could the Agency remind the reference of the requirement imposing on Design Approval
Holders to provide persons and organisations responsible under Part-M/Part-145 with a list
of significant aircraft components?
The reference to the requirement in the Part-21 and/or Certification Specifications would
ensure consistency of requirements for initial and continuing airworthiness.
The competencies to establish the list of significant aircraft components seem to pertain
rather to the design domain than the maintenance domain.
response
3. Proposed amendments — 3.2. Draft Decision — 3.2.3. Decision 2012/018/R (AMC and GM to
p. 30
Part-CAT) — Point AMC1 CAT.IDE.A.105

AMC1 CAT.IDE.A/H.105, AMC1 NCC.IDE.A/H.105 , AMC1 NCO.IDE.A/H.105
We propose the following change to the wording of the text for the purpose of better
readability:
“The operator should control and retain the status of the instruments, equipment or functions
required for the intended operation, that are not controlled for the purpose of continuing
airworthiness management. Examples of such instruments, equipment or functions could be,
but are not limited to, equipment related to navigation approvals as FM immunity or certain
software versions.”
response

AMC1 CAT.IDE.A/H.105, AMC1 NCC.IDE.A/H.105 , AMC1 NCO.IDE.A/H.105
We also propose that the operator should have a procedure described in the operations
manual in order to define responsibilities.
Proposed text:
“GM1 CAT/NCC.IDE.A/H.105 MINIMUM EQUIPMENT FOR FLIGHT
An operator should define, in its Operations Manual the responsibility to retain and control
the status of instruments, equipment or functions required for the intended operation, that
are not controlled for the purpose of continuing airworthiness management.”
response
4. Regulatory Impact Assessment (RIA) — 4.1. Issues to be addressed p. 31-32

RIA 4.1
Comment:
The proposed text introduces the term “Information Tool (IT)”. At other locations in the NPA
is in referred to as Information Technology (IT), which term is generally used in the industry.
Use the term Information Technology (IT) consistently throughout the text.
response
4. Regulatory Impact Assessment (RIA) — 4.3. Policy options — 4.3.1. Inconsistency in the use of p. 33
the terms ‘Life Limited Parts’ and ‘Service Life Limited Parts’

NPA 2014-04, page 33/44, Regulatory Impact Assessment, paragraph 4.3.1.
Although the terms ‘life limited parts’ and ‘time controlled components’ have been
adequately chosen and defined within the frame of this NPA, it is believed that the
Regulatory Impact Assessment has not been sufficiently developed to shed enough light on
the term ‘critical components’.
The amendment of European regulations should be contemplated in order to deploy the
term and concept of ‘critical components’ so that they are homogenously used throughout
the initial and continuing airworthiness processes for aircraft, engines, and propellers.
The term ‘critical components’ could complement the first two in order to address the issues
specified in the ToR, and in particular the following one about the management of some
components:
The point 145.A.50 ‘Certification of maintenance’ states in the paragraph (d) that:
“A certificate of release to service shall be issued at the completion of any maintenance on a
component whilst off the aircraft. The authorised release certificate “EASA Form 1” […]
constitutes the component certificate of release to service except if otherwise specified in
point M.A.502(b) or M.A.502(e). […].”
In the case of used components removed from an aircraft involved in an accident or incident,
the AMC No 2 to 145.A.50(d) provides the following instructions in the paragraph 2.9:
“Such components should only be issued with an EASA Form 1 when processed in
accordance with [instructions for used aircraft components removed from an aircraft
withdrawn from service] and a specific work order including all additional necessary tests
and inspections deemed necessary by the accident or incident. Such a work order may
require input from the TC holder or original manufacturer as appropriate. […].”
The work order is at the origin of the detailed maintenance records production. The notion
of what is deemed necessary by the accident or incident and who determines it is very
subjective in this AMC:
- Do all components warrant the same attention?
It is neither practical nor feasible to process every component in accordance with a specific
work order when it is removed from the event-related aircraft, soon or later after the
accident or incident. While the case of critical components, including life limited parts and
time controlled components, is not disputed, there should be some flexibility for the other
components.
- Have all stakeholders been identified in order to appropriately define the specific work
order?
The definition of the specific work order may require the participation of stakeholders
usually not involved in this activity, such as the TC holder or original manufacturer, but also
the competent authority. It should be explicitly stated, although it really seems quite self-
evident. Further, the criteria for this involvement should be described (e.g. design approval
holder or original manufacturer for components other than critical ones, and TC holder and
competent authorities for critical components).
As a result of the NPA 2014-04 clarifications, the detailed maintenance records created for
such components will be kept by the person or organisation responsible for the aircraft
continuing airworthiness in accordance with the instructions of the paragraphs (6) or (8) of
the GM M.A.305. They will be retained until the information contained therein is superseded
by new information equivalent in scope and detail, i.e. in most cases they will be kept until
the component is permanently withdrawn from service. Nevertheless, some of these
detailed maintenance records will be retained for some, but not all components:
- Required to be kept for:
- Life limited parts, and
- Time controlled components.
- Not required to be kept for:
- Components subject to the ‘condition monitoring’ primary maintenance process, and
- Components that are not subject to any of the primary maintenance processes described in
the GM M.A.305(d)(2).
Therefore, it appears that some aeroplane components (critical in the sense of the CS-E 15(e)
definition) may be inappropriately assessed and the associated detailed maintenance
records not retained by the person or organisation responsible for the aircraft continuing
airworthiness.
It may result in a misrepresentation of the aircraft continuing airworthiness.
The RIA states:
QUOTE
From the safety perspective, defining the need of records depending on the criticality of a
component is a sensible way of addressing the issue. But ‘critical components’ are not always
defined by the DAH, which could create some uncertainty. […] As a first step, the DAH would
have to define ‘critical components’
UNQUOTE
This proposal provides contributions to solve some issues related to continuing airworthiness
and maintenance records that have not been addressed. It also suggests developments that
are necessary to ensure consistency between initial and continuing airworthiness.
response

page 33/44
4.3.1. Inconsistency
We opt for "Option 0"
Rationale:
There is no safety risk and any change only will add to costs, not to safety.
response
4. Regulatory Impact Assessment (RIA) — 4.3. Policy options — 4.3.3. Different interpretations of
p. 34
the need for ‘back to birth’ traceability

page 34/44
4.3.3. Different interpretations..."back to birth" traceability
We favour "Option 2"
Rationale:
We think "back to birth" never was an acceptable term. On the other any such change only
will add to costs, not to safety, in the end it might be more reasonable to do nothing, opt for
"Option 0".
response
4. Regulatory Impact Assessment (RIA) — 4.3. Policy options — 4.3.6. Lack of guidance on the
p. 35
acceptability of record copies (scanned, photocopy)
comment 17 comment by: Julien ALBRECHT

Hi everybody,
Electronic scanned records should always be at least as readable as originals.
As Director of a Tech Rec scanning company since 2005, we have been facing many cases
where records were already scanned but in so low quality that the electronic format was just
not useable at all.
Every thing had to be re scanned from scratch.

I would recommend such minimum requirements:
- 240 Dpi (storage space is not a problem anymore today).
- Color (Because there is a reason why there are stamps with "Origianl in Red" put on pages.
Scanning in Black and white should always be avoided.
Digital records for Certificates, AD dirty finger prints should be digitally stamped to avoid any
modifications.
Storage of such files should be no more complicated or long than getting back to records.
Storage and indexes provided should be certified as readable/useable in 20 years.
best regards.
response
4. Regulatory Impact Assessment (RIA) — 4.3. Policy options — 4.3.7. Lack of guidance on the
p. 35
acceptability of new technology, such as RFID (Radio Frequency Identification)

Identification) "
be on control.
response
4. Regulatory Impact Assessment (RIA) — 4.4. Analysis of impacts — 4.4.1. Inconsistency in the
p. 36-37
use of the terms ‘Life Limited Parts’ and ‘Service Life Limited Parts’

page 36/44
4.4.1. Inconsistency..."Life Limited Parts" and "Service Life Limited Parts
5. General aviation and Proportionality issues.
You write "no impact is exptected. We say: Of course will there be an impact when anything
else than "Option 0" will be accepted.
Rationale:
No change will ever be free of charge.
response

The result clearly proposes use of "Time controlled components" and "life limited parts and
all the other results.
From an airline standpoint as well as aircraft above the historic limit of 5.700 but 15'000
kg/45'000kg we consider the proposed rule will be simpler.
The recreational community will understandably forward arguments, which explain that it
will be more burden for them without a safety benefit.
This once more shows, that this regulation should probably be limited to scheduled airlines
and truly large aircraft in a first step and EASA should try to solve this problem of "one rule
does not fit all" with the EC in a radical approach.
response
4. Regulatory Impact Assessment (RIA) — 4.4. Analysis of impacts — 4.4.2. Different

interpretations as to which components require an EASA Form 1 or equivalent, and which p. 37
documents are considered equivalent to an EASA Form 1

page 37/44
4.4.2. Different interpretations...EASA Form 1
5. General aviation and Proportionality issues
We think we will be affected as anyone else in the aviation community.
Rationale:
As long as we are part of the system we will be affected.
response
4. Regulatory Impact Assessment (RIA) — 4.4. Analysis of impacts — 4.4.3. Different

p. 38-39
interpretations of the need for ‘back to birth’ traceability

page 38/44
4.4.3. Different interpretations

(5) General Aviation and Proportionality issues
Question:
What is the meaning of "some guidance"?
Rationale:
Guidance never is a problem when it comes as clear statement.
response
4. Regulatory Impact Assessment (RIA) — 4.4. Analysis of impacts — 4.4.6. Lack of guidance on
p. 39-40
the acceptability of records copies (scanned, photocopy)

page 40/44
4.4.6. Lack of guidance...records copies
We favour "Option 1":
Rationale:
At last a statment as regards the fact that not all aviation is equal...
response
4. Regulatory Impact Assessment (RIA) — 4.4. Analysis of impacts — 4.4.7. Lack of guidance on
p. 40-41
the acceptability of new technology, such as RFID (Radio Frequency Identification)

Identification) "
be on control.
response
4. Regulatory Impact Assessment (RIA) — 4.4. Analysis of impacts — 4.4.8. Lack of harmonisation
p. 41
with the FAA requirements in relation to continuing airworthiness records

page 41/44
4.4.9. Safety Recommendation
We go for "Option 0".
Rationale:
It fits, no change is required.
response
4. Regulatory Impact Assessment (RIA) — 4.5. Comparison and conclusion — 4.5.1. Comparison
p. 42-43
of options

Identification) "
be on control.
response

page 42/44
4.5.1. Comparison of options
Many thanks for this table, but it is quite difficult to interprete and because it lacks a final
conclusion. Our conlusion on NPA 2014-04, however, is clear: It contains useful parts, but
extensive re-work is required and the applicability to General Aviation of many of the
proposed future provisions by General Aviation specialists is of utmost importance to this
segment of aviation.
Rationale:
Only rarely the specifities of General Aviation were catered for, too many parts of the
proposed texts were more or less directly broken down from a big airliners to an non-
complex aircraft mostly operating in VFR/VMC conditions within the structure of a group or
club for sports or recreational flying.
, particularly due to the "-" values used.
response
4. Regulatory Impact Assessment (RIA) — 4.5. Comparison and conclusion — 4.5.2. Safety
p. 43
Recommendation

page 43/44
4.5.2 Safety Recommendation
We would like to add in this place that we urgently ask all competent authorities to accept
that recommendations are recommendations, not more, not less. We heard this repeatedly
during the past months, e.g. when dealing with piston-engines TBO. Recommendations
never were meant to be hard law, so please comply with this fact at all levels, in doing so you
help to stop the decline of General Aviation we face in many member states, caused by high
costs, administrative burdens, interpretations, discrepancies in the application of the ever-
growing number of provisions of all kinds applicable in many cases to the oldest form of
flying machines, the balloons, to the largest and newest transport aircraft of our times.
response
5. Appendix A — Attachments
5. Appendix A — Attachments
EASA NPA 2014-04 — AWG.pdf

Attachment #1 to comment #373
SB_25-617 flow chart.pdf

AC134_1404.pdf
ADF_F-2005-164.pdf
OCR_1404.pdf
captain seat actuator.pdf

DOSSIER DFP.PDF

CRD 2014-04

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European Aviation Safety Agency

Comment-Response Document 2014-04

1. Procedural information .................................................................................................................................... 3

1.2. The structure of this CRD and related documents

1.3. The next steps in the procedure

2. Summary of comments and responses

3. Draft AMC/GM (draft EASA Decision)

1. ‘CONTENTS’ is replaced by the following:

SECTION A — TECHNICAL REQUIREMENTS

SUBPART C — CONTINUING AIRWORTHINESS

GM M.A.305 Aircraft continuing-airworthiness record system

SUBPART D — MAINTENANCE STANDARDS

AMC M.A.501(b) Installation

SUBPART F — MAINTENANCE ORGANISATION

AMC M.A.615(b) Privileges of the organisation

SUBPART G — CONTINUING-AIRWORTHINESS MANAGEMENT ORGANISATION

AMC M.A.711(a)(3) Privileges of the organisation

SUBPART H — CERTIFICATE OF RELEASE TO SERVICE (CRS)

SUBPART I — AIRWORTHINESS REVIEW CERTIFICATE

SECTION B — PROCEDURE FOR COMPETENT AUTHORITIES

SUBPART C — CONTINUING AIRWORTHINESS

SUBPART D — MAINTENANCE STANDARDS

SUBPART F — MAINTENANCE ORGANISATION

AMC M.B.604(b) Continuing oversight

SUBPART G — CONTINUING-AIRWORTHINESS MANAGEMENT ORGANISATION

SUBPART H — CERTIFICATE OF RELEASE TO SERVICE (CRS)

SUBPART I — AIRWORTHINESS REVIEW CERTIFICATE

AMC AND GM TO THE APPENDICES TO PART-M

APPENDICES TO THE AMC AND GM

2. New GM M.A.305 is added

GM M.A.305 Aircraft continuing-airworthiness record system

organisation for maintenance of components (workshop) to return the component to a specified

3. New AMC M.A.305(a) is added as follows:

AMC M.A.305(a) Aircraft continuing-airworthiness record system

4. New AMC M.A.305(b)(1) is added as follows:

AMC M.A.305(b)(1) Aircraft continuing-airworthiness record system

5. New AMC M.A.305(c)(1) is added as follows:

AMC M.A.305(c)(1) Aircraft continuing-airworthiness record system

6. New AMC M.A.305(c)(2) is added as follows:

AMC M.A.305(c)(2) Aircraft continuing-airworthiness record system

7. New GM M.A.305(c)(2) is added as follows:

GM M.A.305(c)(2) Aircraft continuing-airworthiness record system

8. AMC M.A.305(c)(3) is added as follows:

AMC M.A.305(c)(3) Aircraft continuing-airworthiness record system

9. AMC M.A.305(d) is deleted:

AMC M.A.305(d) Aircraft continuing airworthiness record system

10. AMC M.A.305(d)(4) and AMC M.A.305(h) is deleted:

11. New GM M.A.305(d) is added as follows:

GM M.A.305(d) Aircraft continuing-airworthiness record system

Maintenance task from the maintenance Type of component Continuing-airworthiness

LLP — Current status (M.A.305(d)(1));

12. New GM M.A.305(d)(2) is added as follows:

GM M.A.305(d)(2) Aircraft continuing-airworthiness record system

Primary maintenance process Continuing-airworthiness records

LLP — Current status (M.A.305(d)(1));

Hard time — Current status (M.A.305(d)(2));

On-condition — Current status (M.A.305(d)(2)); and

Condition monitoring EASA Form 1 does not need to be kept unless

13. New AMC M.A.305(e) is added as follows:

AMC M.A.305(e) Aircraft continuing-airworthiness record system