July 2015 Future Defence Aviation Safety Regulation Module 4 - EMAR Part 145 – Maintenance Organisations.

July 2015

Future Defence Aviation Safety Regulation Module 4 - EMAR Part 145 – Maintenance Organisations

EMAR Part 145 – Maintenance Organisations

– Overview of Part 145– Key definitions– EMAR 145 Breakdown– Main differences between TAREG and EMAR

Scope

EMAR Structure

MAWABasic Framework

Document

Engineering & Maintenance Stream Maintenance Training & Authorisation Stream

Initial Airworthiness

Continuing Airworthiness

EMAR 21

EMAR M

EMAR 145

EMAR 66

EMAR 147

145.A.20 Terms of approval (Scope of Organisation)

The Scope Of Approval will be shown in the company Maintenance Organisation Exposition

EMARs use a Classification and rating system grouped into:

– A – Aircraft

– B – Engines/APU

– C – Components

– D – Specialist Services NDT, Arms, Munitions and Pyrotechnic System Specific

Classifications & Ratings

145.A.25 Facilities– Appropriate for the planned maintenance activities including

office accommodation

– Supports personnel effectiveness (working environment, human factors)

– Storage, segregation and access requirements for components, equipment, tools and materials

145.A.30 Personnel Requirements– Accountable Manager (Corporate authority)

– Nominated management team

– Maintenance Man-hour plans and personnel competence standards

– Requirements for limited aircrew maintenance and one-off approvals at remote locations

145.A.35 Certifying Staff and B1, B2 and B Support Staff– Allows for “National Equivalent”

– Licenced by Authority, Authorised to certify by the organisation following competence assessment

– Ongoing competence / continuation training requirements

– Minimum age for certifying staff

145.A.40 Equipment ,Tools and Material– Requirement to have available and use the necessary

equipment, tools and material to perform the approved scope of work

– Use of alternate tools

– Equipment and tools must be permanently available.

– Calibration and control processes required.

145.A.42 Acceptance of Components– Segregation of serviceable and unserviceable components

– Control of unsalvageable/scrap/life expired items

– Component Marking/Labelling requirements

– Pre-installation requirements

– Fabrication of parts

145.A.45 Maintenance Data

– Applicable and current maintenance data

– Requirement to inform author of errors with data

– Requirements for the limited modification of maintenance data

– Availability of maintenance data

– Maintaining the accuracy of maintenance data

145.A.47 Production Planning– All necessary personnel, tooling, equipment, materials,

maintenance data and facilities available

– Requirement to take into account Human Factors when planning maintenance tasks and shifts

– Shift and task handovers to be controlled

145.A.50 Certification of Maintenance

– Certification of Aircraft & Component Release to Service (CRS)

– Reporting requirements to the Continuing Airworthiness Management Organisation (CAMO) for new defects

– Requirements for Deferred Maintenance

– Use of components without appropriate certification

145.A.55 Maintenance Records

– Recording of maintenance work

– Maintenance records reporting requirements to the CAMO

– Retention of maintenance records

– Storage and protection requirements for records

145.A.60 Occurrence Reporting– External (authority) reporting requirements for safety issues

– Internal reporting of error/hazards/unsafe conditions

– Trends analysis and continuous improvement requirements

– Reporting timeframes

145.A.65 Safety and Quality Policy, Maintenance Procedures and Quality System– Requirement for a safety and quality system, including

– Independent auditing requirements

– Internal feedback and response system for addressing findings

– Human factors and performance management

– Maintenance management procedures encompassing 145.A.25-.95

– Minimise multiple errors and critical systems

145.A.70 Maintenance Organisation Exposition (MOE)– Approved by the NMAA

– Description of organisation structure, scope of approval, quality system, maintenance procedures (high level procedures), terms of reference and MOE amendment process

– Safety & Quality Policy

– Can be from an approved EASA Part 145 organisation. Military aspect still need to be covered

145.A.75 Privileges of the organisation

– Maintain any aircraft and/or component for which it is approved at the locations identified in the approval certificate and in the MOE

– Subcontracting of maintenance

– Issue Certificate of Release to Service (CRS) as per 145.A.50 on completion of maintenance.

145.A.80 Limitations on the organisation

– The organisation shall only maintain an aircraft or component for which it is approved when all the necessary facilities, equipment, tooling, material, maintenance data and certifying staff are available.

145.A.85 Changes to the organisation

– Which changes require notification to be made to the authority

– Name change, location changes, management changes

– Anything that could affect the approval

– Ownership of the approved organisation.

145.A.90 Continued validity of the approval

– Unlimited duration based on

– Satisfactory handling of findings

– The NMAA being granted Access

– Certificate of approval has not been surrendered or revoked

145.A.95 Findings

– Level 1 and Level 2

– No observations or opportunities for improvement

– Requirement for corrective action plan within defined timeframes

Differences between TAREG and EMAR

TAREGs 4-5 EMAR Part 145

• Unique to TAREGs 4-5

• Common aspects that require no further explanation

• Common aspects that are treated differently and require further explanation

• Unique to Part 145

Organisational Differences

Current Organisation under TAREG

Possible organisation under EMAR 145 / M

Notes

TAR (Technical Airworthiness Regulator)

NMAA (National Military Airworthiness Authority)

AEOApproved Design Organisation• Design• Certification

Possibility for some personnel performing CAMO functions in SPO’s to “move” into CAMO

No single organisation

Continuing Airworthiness Management Organisation (CAMO)

• CI Management• Maintenance System

(approved data)• Management/selection of

designs onto platform(s)

CAMO created. CAMO responsible for continuing airworthiness.

Some CAMO tasks currently performed by SPO / Through Life Support Contractors (Lean SPO) SQN’s.

Current Position under TAREG

Possible Position underEMAR 145

Notes

Senior Executive Accountable Manager (AM)

Normally mean Chief Executive Officer / senior military commander.

AM has corporate authority for ensuring that all maintenance activities can be financed and carried out.

SMMSenior Maintenance Manager (Responsible Manager) – XXX

SMM’s would have defined responsibilities. For example: • An entire unit/organisation, • Deeper Level Maintenance (Base Maint.), • Flightline Maintenance, (Line Maint.)• Multiple SMMs’ is acceptable with each having specific

responsibilities and no overlapping of authority.

QM QMThe QM needs to be a direct report to the AM. • Responsible for personnel authorisation management

Maintenance Personnel Maintenance Personnel Otherwise referred to as ‘support staff’ in EMARs. 

Maintenance Positions

Current Artefact EMAR 145 / Possible Term Notes

AMO AMOSome current AMO tasks become the responsibility of the

CAMO

MMPMaintenance Organisation

Exposition (MOE) 

Training Records (includes Record of Training and Employment (RTE))

EMARs would permit an ADF equivalent system i.e current practice, in lieu.

Solution yet to be confirmedLicences could be introduced for maintenance personnel and/or current system retained/revised, etc.

Note: RTE is not regulated by TAREG

Maintenance Release Certificate of Release to ServiceSimilar intent however, EMARs application may promote greater flexibility

Maintenance records Maintenance records  

Defect Reports Occurrence reporting

Derogation No direct equivalent A built in flexibility or alternate requirement

Maintenance Artefacts and Approvals

EMAR Part 145Key differences to TAREG– Sponsor (TAREG 4.1.2).

– There is no Sponsor under EMAR– Foreign object (TAREG 4.4.1.a(9)) and tool control (TAREG 5.4).

– Foreign object and tool control (ADF Unique requirement)– Independent Maintenance Inspection (IMI) Certification (TAREG 5.1.3).

IMI’s are not specifically covered under EMAR 145 (yet), (ADF Unique requirement)

– Fleet planning/maintenance scheduling. Despite there being no applicable TAREG, there is an implied AMO responsibility for these functions, which are typically the domain of the SPO, WG, Maintenance Co-ord or unit Maintenance Control Section (MCS). EMARs address these requirements under Part M.

– Responsibilities. Some responsibilities for functions performed at AMO’s lie with the CAMO. (Deferred Maintenance Management, Records Management, Pre-flight inspections)

Questions/Discussion?