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Approvals & Standardisation Directorate Standardisation Department

Cologne 9 and 10 th of September 2008. Part-66 / Part-147 Standardisation Meeting. Approvals & Standardisation Directorate Standardisation Department. Part-66/147 Standardisation Meeting. Open & Welcome by Francesco Banal / François Janvier Approvals and Standardisation Director.

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Approvals & Standardisation Directorate Standardisation Department

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  1. Cologne 9 and 10th of September 2008 Part-66 / Part-147Standardisation Meeting Approvals & Standardisation DirectorateStandardisation Department

  2. Part-66/147 Standardisation Meeting Open & Welcome by Francesco Banal / François Janvier Approvals and Standardisation Director

  3. Rearview mirror • 4th EASA Standardisation Meeting on Part-66/-147. • This is a Standardisation meeting, not a Rulemaking one. • All EASA Member States have been inspected in accordance with the 736/2006 • Total of 18 inspections covering Part-66/ Part-147 during 2007. • During 2008 a total of 12 inspections have been performed till present date. • This is “your” forum! • NAA Feedback Questionnaire

  4. New Basic Regulation: Main Changes • New Basic Regulation, Regulation (EC) No 216/2008 of 20 of February 2008, has been published and entered into force on 8 April 2008. Main Changes • Inclusion of: - Pilots (Article 7, Article 21); - Air Operations (Article 8, Article 22); - Aircraft used by a third-country operator into, within or out of the Community (Article 9, Article 23) - Oversight and enforcement (Article 10)

  5. New Basic Regulation: Main Changes • Introduction of Qualified entities (Article 13) For allocation of a specific certification task to a qualified entity the Agency or the NAA concerned shall ensure compliance with the criteria of Annex V to Basic Regulation. • Changes in the Recognition of certificates (Article 11) The Commission, on its own initiative or at the request of a Member State or of the Agency, can decide whether a certificate issued in accordance with Basic Regulation effectively complies with the Basic Regulation and its implementing rules. In case of non-compliance or ineffective compliance paragraph 1 of Article 11 ( Mutual recognition) shall cease to apply to the concerned certificate.

  6. Follow-up of a supplementary report Infringement procedure 3rd option EU Commission Government 2nd option Request of clarifications Supplementary report 1st option The 4th option! De-recognition of certificates (new art. 11) EASA NAA 6 6

  7. Agenda DAY 1 Tuesday 9.9.2008 • 13.00 Venue and registration • 14.00 Opening & Welcome, General Introduction • 14.30 SINAPSE • 15.00 Review of Part-66 Standardisation issues • 16.30 Coffee Break • 17.00 Review of Part-66 Standardisation issues • 18.15 Update on Examination Credits • 18:30 Conclusions of the day • 19.00 End of day 1 20:00 Get together

  8. Agenda DAY 2 Wednesday 10.9.2008 • 9.00 Venue • 9.30 Upcoming NPAs regarding Part-66 and Part-147 • 10.00 Review of Part-147 Standardisation issues • 11.00 Coffee Break • 11.30 Review of Part-147 Standardisation issues • 12.30 Feedback on open issues from previous meetings • 13.00 Conclusions • 13.30 End of meeting

  9. Standardisation Meeting EASA Standardisation Community Presentation of SINAPSE by Sascha Oliver Schott

  10. Why? EASA standardisation activities should be performed in a transparent and efficient manner EASA should facilitate the sharing of information and NAA experience in applying the common rules One means: Standardisation Meetings like this one! And in between? 10

  11. So what is… …SINAPSE? A software developed and run by the EC, free-of-charge and readily available, accessible via the Internet with personal login, with information posted by communitymembers for the mutual exchange of information, featuring i.e. a document library, discussion forum, surveys, calendar of events automatic e-mail notification of changes. 11

  12. SINAPSE: Main Features 12

  13. Contents? Links to latest regulations & amendments Standardisation inspections procedures & bulletins Standardisation training material Annual standardisation programme Calendar of standardisation events (e.g., Standardisation Meetings, Standardisation Inspector training courses) List of qualified Standardisation Team Members Standardisation Meeting Minutes & Agreed Practices NAA Information Network 13

  14. And who… …should be member of the EASA Standardisation Community? National Coordinators (and Focal Points) Qualified Standardisation Team Members Nominated NAA technical experts(Part-21, -M, -145, -66, -147)… You! 14

  15. Part-66/147 Standardisation Meeting Inspection Results on Part-66 and Part-147 by Edmund Bohland Continuing Airworthiness Standardisation Manager

  16. 2007 SI Results, including 1st Semester of 2008 • Non-compliance findings classes (c), (d) and (f) by Part

  17. 2007 SI Results, including 1st Semester of 2008 • Non-compliance findings class (d) by Part

  18. Supplementary Reports • Until the present date a total of 12 Supplementary Reports were issued, 6 during 2007 and 6 during 2008. • They were mainly linked to deviations in the timely implementation of agreed actions by the NAAs.

  19. Part-66 Main Findings • Licence Conversion process not well defined in Member States (start date, end date, amount of licences to process; Conversion Reports criteria, type of limitations, etc) • Conversion Reports not in line with the requirements (missing elements of Conversion Report as per 66.B.305 and / or 66.B.310) • Limitations on Converted Part-66 Licences not in line with Part-66 requirements (Maximum Take Off Mass dependent, Company dependent, etc) • Missing examination credit report in relation to credit given against basic knowledge • Part 66 AML issued not in line with the requirements (Format of the licence, type ratings in Category A licences, limitations, etc)

  20. Part-147 Main Findings • Basic knowledge examination standard not in line with Part-66 and Part-147 (splitting examination of modules, level of examination questions, number of examination questions, marking) • Personnel requirements: instructors and examiners qualifications, continuing training, acceptance by NAA. • Variability of Part 147 Type Training standards (approval of Type training covering only theoretical elements, practical elements of training not Part-147 approved, duration of type training courses not appropriately defined/controlled, access to the aircraft types not ensured).

  21. Part-66 Standardisation Meeting Introduction to Agenda Items by Edmund Bohland Continuing Airworthiness Standardisation Manager

  22. Standardisation Meeting • In order to reach some tangible results, this forum will have to focus on a limited selection of major current issues, either • raised by the Standardisation Teams in their on-going activities • Or proposed by the Member States in the preparation of this meeting • It was not possible to include in this forum all proposed items by Member States.

  23. Part-66/147 Standardisation Meeting • Belgium • Denmark • Greece • Iceland • Malta • Norway • The following countries communicated topics: • Poland • Serbia • Sweden • Switzerland • UK

  24. Issues in the Day 1 – 09/09/2008Part-66 • 66.A.70(c), 66.B.30x Limitations on converted Part-66 licences Some limitations included in Part-66 licences during the conversion process are not in line with Part-66 requirements. • 66.B.100, Appendix 1 Module 10.7.Some MS are using this item of Module 10 as a tool to prevent mutual recognition of certificates and / or Part-66 licences. • 66.A.30, 66.B.100(a) The experience requirements as per 66.A.30 should be verified by the competent NAA before issuing the respective Part-66 licence. How it is defined, documented or recorded?

  25. Issues in the Day 1 – 09/09/2008Part-66 (contd.) • 66.A.10 Application for Part 66 AML. It’s happening more and more that nationals from one MS apply for an AML to another MS: a common approach is then necessary • 66.B.120 Renewal of AML after its expiry date. The case of renewal of an expired AML is dealt with. • 66.A.45 (c) Type training courses approved by the Competent Authority. An uniform approach is needed when NAA are approving type rating courses

  26. Issues in the Day 2 – 10/09/2008Part-147 • 147.A.300 (g) Approval of type rating training courses not on the complete aircraft. Reach a common understanding on how to deal with this particular training courses. • 147.A.300 Aircraft Type Training, approval of Difference Courses. Try to establish an agreed practice regarding the approval of difference courses. • 147.A.105 (f) (g) Personnel requirements:instructors and examiners qualification. Discuss how each CA is establishing the “officially recognised standard”. Clarify the use of Form 4. • 147.A.145 (a) Recognition of Certificates.Clarify that Certificates of Recognition shall be accepted without further evidence.

  27. Part-66 Standardisation Meeting Agenda Items by Luis Pires Gian Andrea Bandieri Standardisation Team Leaders

  28. Part-66 Issue 1:66.A.70(c), 66.B.30x Limitations on converted Part-66 licences . • According to 66.A.70(c), Part-66 licences based on the conversion of national qualifications shall contain, where necessary, limitations: • Of technical nature. • In relation to the scope of the pre-existing qualification. • This means that only technical limitations should be imposed and in those areas where the competent authority has found that the former qualification standard in the Member State did not meet the Part-66 qualification standard. • During the Standardisation Inspections it was found that some Member States impose limitations not in line with Part-66 requirements.

  29. Part-66 Issue 1:66.A.70(c), 66.B.30x Limitations on converted Part-66 licences . • Some examples are: • Limitations with relation to Maximum Take Off Mass (only aircraft below 5700 Kg). This limitation is not in line with Part-66. Basic Knowledge requirements are not MTOM dependent. • Limitation to a specific country or specific company. This kind of limitation is not of technical nature. • Some limitations are linked to the exercise of privileges, e.g. Airworthiness Reviews (M.A.707) and Certificate of Release to Service (145.A.50). This kind of limitation is not of technical nature.

  30. Part-66 Issue 1:66.A.70(c), 66.B.30x Limitations on converted Part-66 licences . • EASA RECOMMENDATION: • Review the limitations included in the conversion reports and make sure that they are not violating the requirements; • Review previously issued Part-66 licences where limitations imposed are not of technical nature;

  31. Part-66Issue 1 Conclusions(Agreed practices, Common understanding,Clarifications) • Common understanding reached: • Only limitations based on 5700 kg were more controversial • If not, other positions expressed:

  32. Part-66 Issue 2:66.B.100, Appendix 1 Module 10.7 • In Part-66 Appendix I Module 10 item 10.7 requires knowledge examination on applicable National and International Requirements for several subjects. • It is also stated that this is a requirement if the respective subject is not superseded by EU requirements. • Some Member States are using this requirement to prevent mutual recognition of Part-66 licences or certificates issued by Part-147 approved organisations . • This practice is not acceptable and is not in line with the requirements of Basic Regulation (article 11 item 1.).

  33. Part-66 Issue 2:66.B.100, Appendix 1 Module 10.7 • Furthermore, all Module 10.7 knowledge requirements are currently covered by EU requirements: AMP – Covered by Part-M, EU-OPS and Part-145; MMEL – Covered by EU-OPS ADs – Covered by Part-21 SBs – Covered by Part-21 and Part-145 (Maintenance Data) Modifications, Repairs – Covered by Part-21 Maintenance Documentation – Covered by Part-21, Part-145 Continuing Airworthiness – Covered by Part-21, Part-M Test Flights – Covered by Part-21 ETOPS – Covered by EU-OPS All Weather Operations – Covered by EU OPS

  34. Part-66Issue 2 Conclusions(Agreed practices, Common understanding,Clarifications) • Common understanding reached: • YES • If not, other positions expressed:

  35. Part-66 Issue 3:66.A.30(c) - Breakdown of tasks and documentation to be used to record the basic experience • Standardisation Inspections showed that records of basic experience are often insufficient to give a reasonable understanding of where, when and what maintenance constitutes the experience. • Some NAAs have adopted a Logbook trough a national AMC, although the use of Logbooks is not widely utilised therefore many information are missing • Sometimes the simple statement “X years maintenance experience completed” is accepted 35 35

  36. Part-66 Issue 3:66.A.30(c) - Breakdown of tasks and documentation to be used to record the basic experience • Currently there is only a recommendation in AMC 66.A.10 to record practical experience in a logbook. • The purpose is to gain sufficient experience in the environment of commercial maintenance as opposed to only the training school environment. • To that end it’s necessary to define a minimum of what is a “representative cross section of maintenance tasks” • ED 2007-18/R already includes a recommendation to use a Logbook to record continuous experience • NPA 2007-07 is making the Logbook one of the possible options to record Type practical training 36 36

  37. Part-66 Issue 3:66.A.30(c) - Breakdown of tasks and documentation to be used to record the basic experience EASA recommendation: • Extend the use of the Logbook also to basic experience • The same detail as proposed by NPA 2007-07 may be adopted for basic experience • A minimum list of maintenance tasks should be defined (guidance could be found in ICAO Doc7192, Chapters 10-13) 37 37

  38. Part-66 Issue 3:66.A.30(c) - Breakdown of tasks and documentation to be used to record the basic experience Comment from the floor: • Please report your national requirements, if any, for: • Defining the representative cross section of maintenance tasks • Recording the basic experience 38 38

  39. Part-66 Issue 3:66.A.30(c) -Breakdown of tasks and documentation to be used to record the basic experience AP.66.10 - already exists Maintenance experience should be written up in a manner that the reader has a reasonable understand of where, when and what maintenance constitutes the experience. 39 39

  40. Part-66 Issue 3:66.A.30(c) - Breakdown of tasks and documentation to be used to record the basic experience • Common understanding reached: • If not, other positions expressed:

  41. COFFEE BREAK please be back in 30 minutes

  42. Part-66Issue 4:66.A.10 Application for Part-66 licence. Present your view on the following statements: • 66.A.10 establish that an application for an AML shall be made on EASA form 19 and in manner established by the competent authority and submitted thereto, where the competent authority shall be the authority designated by the Member State to whom a person applies; • There are situations where the applicants qualifies in one MS and goes to another MS only to have a Part-66 licence issued by this MS. • Only in the case of the amendment to an AML the rule indicates that the application shall be made to the competent authority that issued the AML.

  43. Part-66Issue 4:66.A.10 Application for Part-66 licence. • Examination of basic knowledge modules performed at a Part-147 organisation shall be accepted; • In case of any doubts or confusion, NAA should discuss their concerns and assist each other as per 66.B.25 “Mutual Exchange of Information” • In case of any suspicions regarding the training and / or the examinations obtained in other MS the MS to which the person is applying can use the provisions of article 10 item 1 of Basic Regulation.

  44. Part-66Issue 4:66.A.10 Application for Part-66 licence. • EASA RECOMMENDATION: • Training by an approved Part-147 (by MS or directly by EASA) shall be accepted; • Examination of basic knowledge modules completed with a Part-147 organisation shall also be accepted; • Examination of basic knowledge modules completed at a Competent Authority can only be used for licence application to that authority. • Assist to each other and exchange information as per article 11 of BR and 66.B.25; • As last resort use BR article 14(1) in case of a safety problem.

  45. Part-66Issue 4 Conclusions(Agreed practices, Common understanding,Clarifications) • Common understanding reached: • If not, other positions expressed:

  46. Part-66 Issue 5:66.B.120 – Renewal of AML validity in case of expired licence. • Clarification has been requested for this particular case, which is thought to be of general interest 46 46

  47. Part-66 Issue 5:66.B.120 – Renewal of AML validity in case of expired licence. Clarification of the rule: • The qualification recognised through the Aircraft Maintenance Licence never expires. • A valid licence is needed to exercise the related privilege, namely to sign a CRS. • An expired licence can always be renewed, provided 66.B.120 is complied with. 47 47

  48. Part-66 Issue 5:66.B.120 – Renewal of AML validity in case of expired licence. Clarification of the rule (cont.): • A CRS issued when the Licence is expired is not valid under both Part-66 and Part-145. • Such an occurrence shall activate an enforcement action (suspension, limitation or revocation) according to 66.B.500. 48 48

  49. Part-66 Issue 5:66.B.120 – Renewal of AML validity in case of expired licence. EASA recommendation: The Competent Authority should investigate whether CRS have been issued while the licence was expired. 49 49

  50. Part-66 Issue 5:66.B.120 – Renewal of AML validity in case of expired licence. Comments from the floor: • … 50 50

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