6th Part-66 and Part-147 Meeting (12.10.2010) · Cologne, 12 October 2010 6th EASA Part-66/Part-147 Standardisation Meeting 6th Part-66 and Part-147 Meeting (12.10.2010) Introduction

Cologne, 12 October 2010 6th EASA Part-66/Part-147 Standardisation Meeting

6th Part-66 and Part-147 Meeting (12.10.2010)

Introduction (Thomas Mickler)

Opening (Mark Kieft)

Issue 1 –Transfer of Part-66 files (Peter Udsen)

Issue 2 – Additional Requirements (Andrea Bandieri)

Issue 3 – Third Country Part-66 Applicants (Ludwig Hessler)

Issue 4 – Use of Part-66 for National Privileges (Bram van Driel)


66thth EASA PartEASA Part--66/Part66/Part--147 147 StandardisationStandardisation MeetingMeeting

Welcome

&

Introduction

by

Thomas MicklerHead of Standardisation Department


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Head ofStandardisation

Head ofStandardisation

Air OperationsG. Rebender

Air OperationsG. Rebender

Accreditation J. Müller

Accreditation J. Müller

Flight Crew LicensingG. De Crescenzo

Flight Crew LicensingG. De CrescenzoAirworthiness

M. KieftAirworthiness

M. Kieft

Deputy HoDM. Kompare

Deputy HoDM. Kompare

SecretariatSecretariat

Standardisation Department (October 2010)

DevelopmentC. Trevisan

DevelopmentC. Trevisan

ATM/ANSN.N.

ATM/ANSN.N.

IAWIAW CAWCAW



A balanced Standardisation Strategy (3 Pillars)

Pillar No 1: Standard. Inspections (reactive)Pillar No 2: Proactive Measures

- Standardisation Meetings - Technical Training of NAA Inspectors - Information Sharing Tool (Sinapse) - Participation of NAA inspectors as team members - Consultation mechanism for NAAs, etc.

Pillar No 3: Evaluation of Impact of Regulations (feedback mechanism)

Evolution towards risk based CMA



Have a successful meeting…….

6th Standardisation meeting Part-66/Part-147

Introduction – Mark Kieft

12 + 13 October 2010

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European Aviation Safety Agency

Welcome

Reorganisation

Who we are

What we will discuss

How we will do this

General rules

The future

What’s new

The social event

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This is YOUR meeting

This is your chance to

Share best practices

Explain your situation

Learn from others

Discuss the interpretation of the rule

Highlight problems to EASA

Provide constructive feedback

Come to a common understanding

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Please make full use of this opportunity

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Reorganisation

Continuing Airworthiness Standardisation Manager

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Reorganisation

Continuing Airworthiness Standardisation Manager

(since April)

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ReorganisationAll 1702 and 2042 scope in one section

To reduce the number of sections ready for the extension of standardisation to ATM/ANS and ADM

To create a dedicated accreditation section

To reduce the inspection burden

To be in line with ICAO USOAP

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S 1 – Standardisation Department Team

Standardisation Coordination Assistants:

Laurence Blasch-Roussel Javadian Agnes Gabriele Klar Susan Schulien

Standardisation Secretaries:

Kathryn Dowling

PenelopeMamopoulou

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Head of

Standardisation Department Thomas Mickler

Deputy Head of

Standardisation Department Marcel Kompare

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S.1.1 - Airworthiness Section

STL Luis Pires

Manager MarkKieft

STL Tore

Sandbu

STL Bram

van Driel

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STL Ludwig Hessler

STL Gian Andrea

Bandieri

STL Peter

Gernandt

STL Chris van Lieshout

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STL Stefano

Bernardini

STL Jean-Luc Rieni

STL Carmen Chirita

STL Peter Udsen

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Agenda – flexible!

DAY 1 Tuesday 12 October 2010 13:15 Opening and Welcome

13:30 GENERAL INTRODUCTION

14:30 ISSUE 1 – Transfer of 66 licenses

15:00 Coffee break

15:30 ISSUE 2 – Criminal records and health certificates

16:00 ISSUE 3 – Applications for 66 from outside the EU

16:30 ISSUE 4 – National privileges on a 66 license

17:00 WRAP-UP OF THE DAY

19:30 Social Event

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Agenda – flexible!DAY 2 Wednesday 13 October 2010

09:00 Arrival

09:15 Rulemaking update

09:45 ISSUE 5 – Type training before basic license

10:15 ISSUE 6 – Web based training

11:00 Coffee break

11:30 ISSUE 7 – General Aviation training and examination

12:15 Team member qualification and currency

12:30 Questions and answers

13:00 CONCLUSIONS OF THE MEETING

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General Organisation

Mobile Phones – “Mute/Off” Please complete the list of participants (check contact details

– phone/e-mail etc) Business cards in tray – 1x is enough. We will copy to all

participants after the meeting Questions to be asked – at any timeWe welcome your opinions – at any time Moderator of the meeting – time management is important Everybody can talk and ask – but not all at the same time... Final publication of the MoM and presentations on SINAPSE Breaks – flexible Please complete the feedback questionnaire

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Mutual expectations during a standardisation inspection

We are working on a document, which will be provided prior to an inspection

Clarifies what is expected of an NAA, and what an NAA can expect of us

Covers all 5 phases of an inspection

Gives advice to the NAA on how best to manage an inspection, and the inspection team

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Inspections – what we expect

During the planning phase – timely information

During the visiting phase – excellent understanding

During the reporting phase – proof-reading and comments

During the follow-up phase – an action plan

During the closure phase – timely evidence of action plan implementation

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What is an acceptable action plan?

Following an inspection final report2 weeks to present a CAP for class D findings10 weeks to present a CAP for class C findings16 weeks to gain an agreement of the CAP

Many cases exist of the CAP being inadequate

Following the inspection, we expect the NAA to carry out a root-cause analysis of the finding – before submitting a CAP

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The CAP should indicate the root-cause analysis, including indicating whether the finding was a one- off, or a systemic error

The CAP should correct the immediate situation (e.g. the certificates will be re-issued), and prevent re- occurrence (e.g. procedure changed)

The CAP should indicate a timeframe by which actions will be completed (these timeframes should be in the future)

The CAP should be simple to understand, simple to implement, and simple to verify implementation

The CAP should only fix the finding’s root-cause, and not all the problems in the NAA

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My team will do everything possible to support the NAAs in perfecting the CAP, but cannot –Do the root-cause analysisPropose actions or datesGive any extensions to the acceptance

timeframes

Non-acceptable CAPs after 16 weeks can only lead to a supplementary report!

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Other AIR standardisation meetings this year

M and 145 on 31 May – 1 JuneM and 145 on 3/4 November21 POA on 2/3 December

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How many standardisation meetings a year?

This year, we have 4 standardisation meetings

Is this the right amount?

Is this the best way to split the regulations?

Would it be better to have 1 or 2 ‘super’ AIR meetings a year?

Will be consulting you on how best to cover the AIR scope at future meetings

Your ideas would be welcomed!

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5th POA Standardisation MeetingStandardisation plan 2011

Plan is approved Now arranging specific datesSome inspections over 2 weeksAll combined inspectionsAll with POA includedContribution of team members has been

requested – once finalised, will be set in stone

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NEW THIS TIME – “Conclusions”

We used to use the term “Agreed Practices”

The term was not liked

Now called “conclusions”

Same intent

Not legally binding, but mutually desiredTo achieve a common understanding“agreed” method of application

Near future - Will go into rulemaking- machine to become AMC

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NEW THIS TIME – proposed conclusion

We want to come to a conclusion on each topic, as this allows you to take something concrete home

However, it is unfair to discuss a topic without you knowing where we are heading

Therefore we have sent the proposed conclusions in advance

Hopefully this will allow you to have better arguments ready at the discussion phase

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NEW THIS TIME – Best practices form

In your folder, there are ‘Best Practices Forms’

These are to collect your ideas related to each topic – not enough time to discuss everything today

We will briefly discuss tomorrow

And will minute in the MoM

Please complete best practices forms to share your knowledge!

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Mathildenstraße 42 50679 Deutz, Köln

0221 812680

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EASA

Brauhaus ohne Namen

Church

Youth Hostel

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Finally

Proactive is better than reactive….So please -participate in, learn from, and enjoy the discussions

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6th Part-66 and Part-147 Standardisation Meeting – Cologne 12 and 13 October 2010

ISSUE 1: Transfer of Part-66 licences from one MS to another MS


Peter Udsen Standardisation Team Leader

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Description of the problem Proposed conclusionHighlights of the relevant regulations Summary Discussion Final conclusion

Items

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Description of the problemA person who has his first AML issued by the

Member State of residence, and then later moves to another Member State. e.g. do to personal reasons.

He wants to change his AML, and wants of course the change be done by the Competent Authority in his new country.But the regulation does not allow this.

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Proposed conclusionCan a Member State extent an AML issued in an

another Member State?

No!

The regulation clearly states that any change to the AML shall be done by the Member State of first issue.

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Any Questions?

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Any Questions?

Can Article 14 be used?

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Any Questions?


Will there be changes to the regulation in the future ?

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Regulation - Part 6666.A.10 Application

(a) An application for an aircraft maintenance licence or change to such licence shall be made on an EASA Form 19 in a manner established by the competent authority and submitted thereto.

(b) An application for the change to an aircraft maintenance licence shall be made to the competent authority of the Member State that first issued the aircraft maintenance licence.

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Regulation - Part 6666.A.10 Application(e) Where the applicant for change of the basic categories qualifies for such change via the procedure referred to in point 66.B.105 in a Member State other than the Member State in which he/she first qualified, the maintenance organisation approved in accordance with Annex II (Part-145) shall send the aircraft maintenance licence together with the EASA Form 19 to the competent authority of the Member State of first qualification for Member State stamp and signature of the change or reissue of the licence.

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In extreme situation where a need can be justified, it is possible to diverge from the regulation, by the use of article 14 in the basic regulation.

But one basic principle stands:

An AML holder can only have one license.

Therefore the condition for the transfer must be:1. The two Member States should agree and cooperate.2. The new Member State becomes the Member State of first issue3. The new Member State shall accept to take duties and

responsibility as Member State of first issue.4. The files of the AML holder shall be transferred to the new

Member State of first issue.5. The new Member State shall issue a new license replacing the

former license.6. The License shall be issued in accordance with Part-66.B.100. 7. The former license shall be accepted as part of the applicants'

knowledge and experience.8. The former Member State shall cancel the former license.

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Proposed change to Part 66There are proposal for changes in Part-66 to

allow the transfer of a license between Member States. Member States

Within a year this change will be enforced.

So until further, follow the current regulation!

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Summary The regulation does not allow the transfer of a

license between Member States.

Article 14 can only be used in special cases.

Change to Part 66 might change to the favour of this issue.

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Final ConclusionFollow the regulations!

Do not use Article 14, excepted in extreme situation.

Hold your hoses, and wait for the change of the regulation.

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ISSUE 2: Additional National Requirements

ISSUE 2: ADDITIONAL NATIONAL REQUIREMENTS

Gian Andrea BandieriStandardisation Team Leader

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Situation

During recent inspections it was found that some NAAs are requiring applicants for Part- 66 Licences to fulfil additional national requirements

These may include:Statement of no criminal recordsHealth certificateEvidence of no abuse of alcohol or drugs

The good intention is evident, however in this case only EU law needs to be complied with

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Proposed conclusions

Imposition of additional national requirements (e.g.: Certificate of no criminal records, Health certificate, compliance with national criminal law in

respect of the abuse of alcohol and drugs)

for the issue of a Part-66 Licence is considered a violation of the European Legislation.

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Legal considerations (1)

Recital (10) of Basic Regulation must be read together with art. 2

In order to achieve Community objectives as regards the freedom of movement of goods, persons and services, as well as those of the common transport policy, Member States should, without further requirements or evaluation, accept products, parts and appliances, organisations or persons certified in accordance with this Regulation and its implementing rules.

Article 2 Objectives1. …2. Additional objectives are, in the fields

covered by this Regulation, as follows:..(f) to provide a level playing field for

all actors in the internal aviation market.

3. The means of achieving the objectives set out in paragraphs 1 and 2 shall be:

d) the uniform implementation of all necessary acts by the national aviation authorities and the Agency within their respective areas of responsibility.

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Aircraft maintenance licences can only be issued in accordance with Part-66

Only Part-66 requirements need to be fulfilled to issue an Aircraft maintenance licence

66.B.100 is the only applicable requirement:a) On receipt of EASA Form 19 and any supporting documentation,

the competent authority shall verify EASA Form 19 for completeness and ensure that the experience claimed meets the requirement of this Part.

b) The competent authority shall verify an applicant's examination status and/or confirm the validity of any credits to ensure that all required modules of Appendix I have been met as required by this Part.

c) When satisfied that the applicant meets the standards of knowledge and experience required by this Part, the competent authority shall issue the relevant aircraft maintenance licence to the applicant. The same information shall be kept on competent authority file.

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To receive an Aircraft maintenance licences the applicant needs only to comply with the standards of knowledge and experience defined in Part-66

NO MORE

NO LESS

As a citizen he has to comply with all other national regulations in force in the country where he works, but a preventative compliance cannot be required by the NAA

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Conclusions

In order to issue a Part-66 Licence, only Part-66 requirements are applicable

Adding national requirements for the issue of a Part-66 Licence violates EU legislation

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Discussion

Do you have any national additional requirements to be fulfilled at the time of application for a Part-66 Licence? If so can you provide us with some example?

Is there any particular reason for linking them to the issue of a Part-66 licence?

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Final conclusions

Do not impose additional national requirements to issue a Part-66 Licence

Requiring: Certificate of no criminal records, Health certificate, compliance with national criminal law (e.g. in

respect of the abuse of alcohol and drugs)

is considered a violation of the European Legislation.

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Issue 3: Part-66 Third Country Applicants

ISSUE 3: Part-66 Third Country Applicants

Ludwig Heßler Standardisation Team Leader

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Description of the problemProposed conclusionHighlights of the relevant

regulationsSummary DiscussionFinal conclusion

Items

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Description of the problemSituation: Mechanics from third countries apply

for a Part-66 licence in Member States in order to:o either work in an organisation approved by the

Member States on EU registered aircrafto or work in EASA approved organisations on EU

registered aircraft which have premises in the Member state.

Problems: EASA Form 19 are not used, certificates issued by 147 approved organisations are not recognised


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Proposed conclusion

Treat applicants equal to applicants from a Member State (EASA Form 19 etc.).

Accept training certificates issued by Part- 147 organisations.


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Highlights of the relevant regulations

66.A.10 Application

(a) An application for an aircraft maintenance licence or change to such licence shall be made on an EASA Form 19 in a manner established by the competent authority and submitted thereto.


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Highlights of the relevant regulations

66.A.25 Basic knowledge requirements(a) An applicant for an aircraft maintenance

licence or the addition of a category or subcategory to such an aircraft maintenance licence shall demonstrate, by examination, a level of knowledge in the appropriate subject modules in accordance with Appendix I to this Part.

The basic knowledge examinations shall be conducted by a training organisation appropriately approved under Part-147 or by the competent authority.


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Summary

Procedures used for applications shall follow the rules.


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Discussion

How many (percentage) applications from non-EU mechanics did you have in the past?

How did you handle these applications?


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Final conclusion

Treat applicants equal to applicants from a Member State (EASA Form 19 etc.).

Accept training certificates issued by Part- 147 organisations.


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Issue 4: Part-66 AML and national privileges

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Issue 4: Use of Part-66 AML in case of national privileges

Bram van Driel Standardisation Team Leader

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Introduction Proposed conclusionQuestions to be answered Highlights of the relevant regulations EvaluationDiscussion Summary Final conclusion

Items

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Introduction Part-66 (form-26) has an optional annex to the AML for

national privileges.

What are the rules or restrictions to use this annex?

Part-66 Appendix VI limits the use of the annex to privileges outside the scope of part-66, covered by national legislation in force prior to Part-66

(nov 2003*).

Different interpretations exist.* Depending opt-out.

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Proposed conclusion

NAA’s are free in the use of the annex.

Use national legislation and procedures for the annex.

Use is irrespective of entry into force of national regulation. (Appendix VI to be amended)

Use is irrespective of the date the privilege was first issued.

National privileges cannot cover part-66 privileges.

National privileges can go beyond Part-66 sub-categories.

The Annex shall not be issued with an empty part-66 AML.

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Questions to answer…Are National privileges in the optional annex:

limited to the the scope of part-66 AML?

limited to type ratings?

limited to conversion?

limited to exisiting regulation?

limited to exisiting privileges?

What is relation to Certification authorisation?

Is national privilege additional burden to holder?

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Highlights of relevant regulations (Part-66 Appendix VI)

‘Aircraft Maintenance Licence (Part-66 AML)

11. The annex to EASA Form 26 is optional and may only be used to include national privileges not covered by Part-66, where such privileges were covered by the national regulation in force prior to the implementation of Annex III (Part-66).’

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Highlights of relevant regulations



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Aircraft Maintenance Licence (Part-66 AML)

11. The annex to EASA Form 26 is optional and may only be used to include national privileges, where such privileges are covered by the national regulation outside the scope of Annex III (Part-66).

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Part-66 Appendix VI

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Evaluation (1)

The intention of the Annex is to allow

- on one licensing document –

both privileges following Part-66 and

privileges not covered by Part-66.

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Evaluation (2)The Annex to Part-66 (Form 26) may be used

for any national privilege,

as defined by national regulations

provided:

The scope of the national privileges is clear.

The national licences clearly do not cover privileges under EU jurisdiction.

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Evaluation (3) Beware of frequent changes in Scope of Part-66:

Opt-out expires (GA)New (sub) categories (“L”) EASA type certificates (prototype) Annex II aircraft (DC 4)

National privileges can go beyond Part-66 sub-categories. Limitations. Types outside the scope of part-66. Covered by national legislation.

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Evaluation (4) Validity of national privileges:

As defined by national and international regulations.

Never applicable to privileges covered by EASA.

Aircraft maintenance of nationally registered aircraft ….around the world.

Possible mutual recognition. (bilateral agreements etc)

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Evaluation (5) The Annex is open for any national privilege. Examples:

Basic rating and/or Aircraft type rating for

EASA aircraft within opt-out period

Annex II aircraft (Vintage, gliders, Balloons etc)

State aircraft

Military aircraft

Component Maintenance Licences Specialised services Ground support licences Etc.

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Evaluation (6) National privilege for Annex II aircraft (some examples):

Aircraft maintenance Gyrocopters

Airframe Breguet 904

Airworthiness inspection

Electrical systems All piston engine a/c

Hydraulics

Nav/com All a/c

Radio ARC 192

Turbine engines PT6

B1.2 Piston engined annex II a/c

National privileges for aircraft engaged in military, customs, police or similar services:

Aircraft maintenance Police helicopters Bo105

Airframe Beech 1900 coastguard

Other National privilege examples:

Workshops (Hydraulics, Electrics, Nav/com, etc)

Specific components (ARC 192, PT6, Wheels, etc)

Radio communication on the ground

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Evaluation (7) To be combined with any Part-66 AML:

A3

B1.1 Line maintenance certifying technician - mechanical - Turbine Aeroplanes.

(Bombardier) Learjet 23 (GE CJ610)(Hawker Beechcraft) Beech 200 Series (PWC PT6)(Hawker Beechcraft) Beech 390 (Williams FJ44)(Hawker Beechcraft) Beech 90 Series (PWC PT6)(Hawker Beechcraft) Beech 99/100 Series (PWC PT6)

B1.4 Line maintenance certifying technician - mechanical - Piston Helicopters.

All Single piston helicopters in group 13.

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Evaluation (8)

No Part-145 and M/subpart-F authorisation for aircraft CRS based on annex.

NAA free to base national authorisation on Part-66 AML (Sub category and group ratings).

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Evaluation (9)

Annex to EASA Form 26XIII. NATIONAL PRIVILEGES outside the scope of Part-66,

in accordance with ‘ministerieel besluit V&W/dcr/123’. (valid only in the Netherlands)

Radio Licence Privileges:Radio operator valid on ground only

Maintenance of Annex II aircraft:Airframe Breguet 904

Example:

EASA Form 26 Issue 2

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Discussion Does your country use this Annex?

Does your country have restrictive use?Within sub-category of Part-66 ratings. No new privileges.

Would you wish to restrict the use to old privileges?

Does your country use Part-66 as basis for national privileges?

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SummaryAnswers to the questions

National privileges in the optional annex:

Can be independent of the scope of part-66 AML.

Are not limited to type ratings.

Are not limited to conversion.

Are not limited to existing national regulation.

Are not limited to existing national privileges.

Have no effect on Certification Authorisations requiring Part- 66 AML.

National privileges may not add requirements to Part-66.

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Final conclusion

NAA’s are free in the use of the annex.

Use national legislation and procedures for the annex.

Use is irrespective of entry into force of national regulation. (Appendix VI to be amended)

Use is irrespective of the date the privilege was first issued.

National privileges can go beyond Part-66 sub-categories.

National privileges cannot cover part-66 privileges.

The Annex shall not be issued with an empty part-66 AML.

6th Part-66 and Part-147 Meeting (12.10.2010) · Cologne, 12 October 2010 6th EASA Part-66/Part-147 Standardisation Meeting 6th Part-66 and Part-147 Meeting (12.10.2010) Introduction

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