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MODULO 10 GUA PARA LA REALIZACIN DE AUDITORIAS INTERNAS DE UNA ORGANIZACIN DE MANTENIMIENTO PARTE 145

Modelo de aeronave / Talleres / etc...


PART 145.25(a)

FACILITY REQUIREMENTS
1. Aircraft hangars available for base maintenance. 2. Proof of tenancy, if the hangars are not owned by the organisation. 3. Sufficiency of hangar space demonstrated by a projected hangar visit plan relative to the maintenance program. 4. Update of aircraft hangar visit plan at regular intervals. 5. Aircraft component workshops large enough to accommodate the components on planned maintenance. 6. Aircraft hangar and aircraft component workshop structures prevent the ingress of the normally prevailing local weather elements, dust, noise, moisture and other air pollution. 7. Aircraft component workshops and aircraft hangars sufficiently heated. 8. Mass points for electric and electronic devices installed. 9. Adequate energy source: Air vacuum, etc 10. Floors sealed 11. Aircraft hangar available whenever there is a need due to the kind of work to be carried out for line maintenance or there are means to stop the work. 12. Aircraft hangars and component workshops separated in such a manner that interacting contamination is prevented. 13. Aircraft hangars and component workshops in a condition to prevent environmental pollution. Pgina 1 de 34

PART 145.25(b)

FACILITY REQUIREMENTS
1. Adequate office accommodations for management, planning, quality staff, workshop management, technical documentation. 2. Adequate means of communication between departments installed. 3. Provisions and accomodation for the maintenance staff to study Maintenance Data and fill-in the maintenance records in a proper manner.

PART 145.25(c)

FACILITY REQUIREMENTS
1. Room temperatures so that the personnel can work without undue discomfort. 2. Working environment such as to ensure the carrying out of work tasks in an effective manner. 3. Working environment meeting the specific requirements to maintenance work. 4. Lighting up to the state of the art. 5. Noise levels such as not to distract personnel from carrying out inspection tasks. 6. Provisions for the case that the working environment deteriorates to an unacceptable level in respect of temperature, moisture, snow, hail, ice, wind, light, solar radiation, to suspend the particular maintenance tasks especially at line maintenance until satisfactory conditions are re-established. 7. Provisions in the case of occurring dust/other airborne contamination ( visible surface contamination) to seal susceptible accessible systems until acceptable conditions are reestablished.

PART 145.25(d)

FACILITY REQUIREMENTS
1. Storage facilities for spare parts, technical equipment, equipment, tools, other material. 2. Unauthorised access Pgina 2 de 34

3. Unserviceable and serviceable components stored separately: labelling, segregation. 4. Storage facilities: clean, well-ventilated and even dry temperature to minimise the effects of condensation. 5. Storage racks of adequate dimensions, strength and stiffness to support large aircraft components so that they are not distorted during storage. 6. Provisions to ensure that aircraft components remain packaged in protective material until installed. 7. Storage instructions established on the basis of the manufacturer storage recommendations. 8. Inspection of incoming goods and procedures for this inspection. 9. Certificates of the origin and the serviceability of spare parts.

PART 145.30(a)

PERSONNEL REQUIREMENTS
1. Nominated Accountable Manager: demonstrate a basic undestanding of PART-145 and the responsabilities associated with being acc. mgr. Acceptable as per DGAC IC 31-08 2. Nominated senior person or persons (maintenance management structure): especially base maintenance manager, line maintenance manager, workshop manager, quality manager. 3. Is the managing staff suitable? Acceptable as per DGAC IC 31-08 JAA Form 4 accepted. 5. Responsibilities for the individual scopes of duties determined; understood at all levels. 6. Has DGAC acceptance been sought for the accountable manager to also act as manager line maintenance and/or workshop manager? 7. Are titles and authorisations of the managerial positions compatible with those used in PART-145 or if not - are the titles and authorisations of the persons notified to the Pgina 3 de 34

DGAC? 8. Procedures should make clear who deputises for any particular manager in the case of lengthy absence of said manager(s). 9.- Is the duty of the accountable manager and of the other senior persons to carry out corrective action on the bases of the results of quality audits (acc. to PART 145.65(b)) laid down in writing? 10.- If there are more managers, they should report ultimately through either the base maintenance manager or line maintenance manager or workshop manager or quality manager to the Acc. Mgr.

PART 145.30(b)
1.- Quality Policy established and promoted by the Acc. Manager. (His responsibility).

PART 145.30(c)

PERSONNEL REQUIREMENTS
1.- Quality Manager nominated by Acc. Mgr. 2.- QM with right of direct access to the accountable manager to ensure that the acc. manager is kept properly informed on quality and compliance matters. Privileges and duties of QM. 3.- Requesting remedial action as necessary by the Acc. Mgr, Base, Line, Workshop, etc...

PART 145.30(d)

PERSONNEL REQUIREMENTS
1. Sufficient staff: planning, performance of the work, quality monitoring, inspections. Employed / Contrated; At least half of staff at each workshop, hanger or flight line -> employed 2. Sufficient number of certifying staff 3. Man-hours plan: demonstrate sufficient manhours for the work that is intended to be carried out (ALL sections of the Organisation) Aircraft/components work ALL operators. Base Maintenance -> relate to the Aircraft Hangar Visit Plan. Component Maintenance -> Pgina 4 de 34

relate to the component planned maintenance. Specified in the MOE. 4. Update of man-hour plan (at least every 3 months and when necessary. 5. Sufficient man-hours for Quality monitoring function [Relevant 145.65(c) sub-paragraphs] Quality Moinitoring Staff performing other functions ? -> Considered in man-hours plan ? 6.- Procedure to reassess work intended to be carried out when actual staff availability is less than planned staffing level for any particular work shift or period. 7.- Plan Deviations: notified ?, (25% shortfall)

PART 145.30(d)

PERSONNEL REQUIREMENTS
1. Procedures for establish & control competence of Maintenance, [Management] and Quality Audit Personnel. (By 'on the job' and/or by examination). 2. Job descriptions for each job role. 3. Planners: are able to interpret maintenance reqs. into maintenance tasks & have no authority to deviate from the maintenance data. 4. Mechanics: able to carry out maintenance tasks to any standard specified in the maintenance data 5. Mechanics: have to report to supervisors mistakes requiring rectification to re-establish required maintenance standards. 6. Specialised service staff: Able to carry out specialised maintenance tasks (i.e. NDT, ) to the standard specified in the maintenance data and will both inform and await instructions from their supervisor in any case it is not possible to complete the specialized maintenance in accordance with maintenance data. 7. Supervisors: able to ensure that all required maintenance tasks are carried out and where not completed or where it is evident that a particular maintenance task cannot be carried out to the Pgina 5 de 34

maintenance data, then such problems have to be reported to the Quality Mgr. for appropriate action. When they carry out maintenance tasks, they understand that such tasks should not be undertaken when incompatible with their management responsibilities. 8. Certifying staff: able to determine, whether an aircraft or a component can be released to service or not. 9. Planners, specialized services staff, supervisors and certifying staff: knowledge of organization regulations and requirements relevant to their particular role in the organisation. 10.- Quality Audit Staff: monitor compliance with PART-145 identifying non compliance in an effective and timely manner. 11.- Competence must include understanding of the application of human factors and human performance issues. 12.- Continuation Human Factors training (All maintenance, Management & Quality Audit personnel) [See req's AMC 145.30(e)5, 7,8 & 9 ] 13.- Initial Human Factors training. [See Appndx 9 and AMC 145.30(e)6, 8 & 9 ]

PART 145.30(f)

PERSONNEL REQUIREMENTS
(NDT Personnel)) 1. Procedures for Qualification (Level 1,2 or 3) of personnel who carry out and/or control a (1) "continued airworthiness non-destructive test" of aircraft structures and/or components for the (2) "particular non-destructive test". (European Standard EN 4179). Exception: equivalent std. in the case of PART145 MO outside JAA full member States. 2. Personnel for any other specialised task -> appropriately qualified i.a. with any existing national std. recognised by DGAC as an appropriate std. Pgina 6 de 34

(1) Continued airworthiness non-destructive testing means such testing specified by the type certificate holder or manufacturer in the PART 145.45 maintenence data for in service aircraft/component for the purpose of determining the continued fitness of the product to operate safely

(2) Particular non-destructive test means any one or more of the following: Dye penetrant, magnetic particle, eddy current, ultrasonic and radiographic methods inlcuding X ray and gamma ray.

3.- Level 3 personnel. qualified via EN 4179 to establish and authorise methods, techniques -> does not permit such personnel to deviate from methods and techniques of the continued airworthiness data (NDT manuals, SBs, unless these allow such deviations). 4.- Personnel qualified in PART-66 sub-category B1 > carry out and/or control contrast dye penetrant tests. 5.- Examinations: conducted by personnel or organisations udner the general control of National aerospace NDT Board. In basence of such a Board the DGAC will make arrangements with another JAA full member Authority to use the NDT Board of that State. 6.- New NDT methods: thermography and shearography (not addressed by EN 4179). Carried out i.a. with the particular equipment manufacturers recomendations including any training and examination process to ensure competence of the personnel with the process. 7.- Non-destructive Inspections: procedure for training and assessment for competence of personnel > Boroscoping and other techniques (delamination coin tapping, etc..)

PART 145.30 (g) 1

PERSONNEL REQUIREMENTS
Line Maintenance (Aircraft MTOW > 5700 KG) 1.- Aircraft type rated certifying staff qualified PART 145.35 plus PART-66 Sub-category B1 and B2. [includes personnel holding protected rights under PART-66.1(d)] 2.- In addition: may use appropriate task trained Certifying staff qualified PART 145.35 plus PART-66 [List of typical tasks permitted after appropriate task training to be carried out by the Cat A for the purpose of issuing category A ==> (1) minor schedule line maintenance a PART-145.50 aircraft CRS --> AMC 145.30(f)(1) 3] Pgina 7 de 34

and simple defect rectification. (This does not preclude of the previous one, to support the Cat A certifying staff except this Cat B1 & B2 need not always be present at the line station during such works).

(1) Minor schedule line maintenance means any minor scheduled inspection/check up to including a weekly check specified in the operators approved aircraft maintenance programme. For maintenance programme that do not specify a weekly check, the JAA full member will determine the most significant check that is considered equivalent to a weekley check.

PART 145.30 (g) 2

PERSONNEL REQUIREMENTS
Base Maintenance (Aircraft MTOW > 5700 KG) 1.- Aircraft type rated certifying staff qualified PART 145.35 plus PART-66 category C. [includes personnel holding protected rights under PART-66.1(d)] In addditon MUST have appropriate task rated staff qualified PART 145.35(b) and (e) plus PART-66 subcategory B1 and B2 to support (2) the category C (2) Support : category B1 staff must be satisfied that all mechanical tasks/inspections have been carried out to the required standard and the category B2 staff must be satisfied that all avionic tasks/inspections have been carried out to the required standard before the category C issues the certifying staff. Register of any such PART-66 subcategory B1 and B2 qualified support staff. 2.- Qualified category B1 and B2: holding an appropriately type rated PART-66 aircraft maintenance licence in either category B1, category B2 or both. Such personnel should, as required by PART 145.30(f)(2) be in compliance with PART 145.35(b) and (e). These personnel need not be certifying staff but the organization may use appropriately qualified certifying staff. 3.- Organisations that prior to PART-66 worked in accordance with National requirements not containing licensing requirements: the organisation should identify in conjunction with the JAA full member those staff considered to have equivalent qualifications to either PART-66 category B1 or B2. Such staff will be considered as supporting the PART66 category C certifying staff and may qualify for the limited PART-66 aircraft maintenance license. 4.- Certifying staff PART-66 category C includes those personnel holding protected rights under PART66.1(d).

CRS. The primary role of Category C is to ensure that all work required has been called up and accomplished. The secondary is to assess the impact of any work not carried out with a view to either requiring its accomplishment or agreeing with the operator to defer such work to another specified check or time limit.

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PART 145.30(h)

PERSONNEL REQUIREMENTS
(Aircraft MTOW < 5700 KG) Until PART-66 specifies a requirement continued compliance with current national aviation regulations of the JAA full member Authority that granted or proposes the grant PART-145 approval.

PART 145.30(i)

PERSONNEL REQUIREMENTS
(Aircraft components) Until PART-66 specifies a requirement continued compliance with current antional aviation regulations of the JAA full member Authority ...

PART 145.30(j)

PERSONNEL REQUIREMENTS
(Special circumstances) 1.- Non-JAA State or non-JAA full member State based PART-145 maintenance organization approved by a JAA full member: may use certifying staff qualified to the national aviation regulations of the State in which is based ==> JAA full member in conjunction with JAA Maintenance Division being satisfied that such regulations result in a standard comparable with PART-66 + JAA additional conditions, where specified. 2.- [RESERVED] for non-JAA State based PART-145 maintenance organisation accepted by the JAA in accordance with PART-145.10(c) 3.- Limited line maintenance carried out by another organization under the quality system of a JAA full member approved organization at a non-JAA State or Non-JAA full member State location ==> (Same as #1 above) Pgina 9 de 34

4.- Repetitive pre-flight airworthiness directive, which specifically states that the flight crew may carry out such AD, the PART-145 approved organization may issue a limited PART-145 authorization to the aircraft commander and/or the flight engineer subject to being satisfied that sufficient training has been carried out to ensure he can accomplish the AD to the required standard. 5.- (1) Unforeseen case of an aircraft grounded at a location not having an appropriate approved or accepted PART-145 organisation ==>issue a one-off PART-145 certification authorization to a person not less than 5 years maintenance experience and holding a valid ICAO aircraft license rated for the aircraft type requiring certification, subject to the PART-145 organisation obtaining and holding on file evidence of the experience and the license. All such cases must be reported to the JAA full member Authority within 7 days after the issuance. Maintenance that could affect flight safety could be required to be rechecked by the contracted PART-145 approved or accepted organisation. (1) Unforeseen: could not be reasonable have been predicted by the operator because the defect was unexpected due to being part of a hitherto reliable system.

PART 145.35(a)

CERTIFYING STAFF
Issuing or re-issuing certification authorization: adequate understanding of the relevant aircraft and/or aircraft components (the ones at his certification authorization) together with the associated organization procedures. Trained received/ relevant maintenance Pgina 10 de 34

experience and exams passed of the product type and associated organization procedures: how the product functions, what are the most common defects with associated consequences. Training and examination may be reduced or eliminated when AMC 145.35(e) subparagraph 3 is taken into account.

PART 145.35(b)

CERTIFYING STAFF
All aircraft release certifying staff are (1) involved in at least 6 months of actual aircraft (1) Involved means he has worked in an aircraft maintenance environment and has either exercised the privileges of the certification authorization and/or has actually carried out maintenance on at least some of the aircraft type systems specified in the particular authorization. maintenance experience in any 2 year period.

PART 145.35(c)

CERTIFYING STAFF
1.- Continuation training: all certifying staff receiving sufficient in each 2 year period. Remain current in terms of organization procedures, knowledge of relevant technology and human factor issues. Feedback: the organization receives feedback on the adequacy of its procedures and maintenance instructions. (Involvement of the quality department to ensure that feedback is actioned OR a procedure to ensure that feedback is formally passed from the training department to the quality department to initiate action. 2.- Continuation training: changes in requirements such as PART-145, in organization procedures; modification standard of the products being maintained; human factor issues identified from any internal or external analysis of incidents. Instances where staff failed to follow procedures and the reasons. Identify to the company incomplete or incorrect procedures. 3.- Continuation training: all certifying staff receive sufficient in each 2 year period. Sufficient duration should be related to relevant quality audit findings and other internal/external sources of information available on human Pgina 11 de 34

errors in maintenance. [Less audit findings the less continuation training will be needed]. Aircraft components: the duration would follow the same philosophy but should be scaled down to reflect the more limited nature of the activity. Review content at least once in every 24 month period. 4.- Method of training: flexible process and could, for example, include a PART-147 continuation training course, aeronautical college courses, internal short duration courses, seminars, etc. The elements, general content and length of such training should be specified in the MOE unless such training is undertaken under a PART-147 approval when such details may be specified under the PART-147 approval and cross referenced in the MOE.

PART 145.35(d)

CERTIFYING STAFF
1.- Programme for continuation training: list all certifying staff, when training will take place, the elements of such training and an indication that it was carried out reasonably on time as planned. Such information should be transferred to the certifying staff record [req'd by PART-145.35(h)] 2.- Procedure to ensure compliance with relevant sub-paragraphs of PART 145.35 as the basis for issue of the certification authorisations, plus, if applicable, a procedure to ensure compliance with PART-66.

PART 145.35(e)

CERTIFYING STAFF
1.Procedure for assessing for competence, qualification and capability related to intended certifying duties all prospective certifying staff (except the one off 145.30(1)(5)), before the issue or reissue of a certification authorisation. 2.Assessment of Competence and capability: working the person under the supervision of either another certifying person or a quality auditor for sufficient time to arrive at a conclusion. Pgina 12 de 34

Sufficient time: depending if the person is fully exposed to relevant work (as little as a few weeks). Persons recruited from another PART-145 approved organisation and was a certifying staff: it is reasonable to accept a written confirmation from the person responsible for running the quality system about the person. 3.- Qualification assessment: collecting copies of all documents that attest to qualification (licence and/or any authorisation held) followed by a confirmation check with the organisation(s) that issued such document(s) and finally a comparison check for differences between the product type ratings on the qualification documents and the relevant product types maintained by the PART-145 organisation (maybe he will need type differences training).

PART 145.35(f)

CERTIFYING STAFF
1.- Certifying staff authorisation documents availability. 2.- Authorisation document clearly show the scope and limits of such authorisation to the certifying staff and any authorised person that may require to examine the authorisation.. 3.- Use of codes ==> code translation readily available.

PART 145.35(g)

CERTIFYING STAFF
1.- Issue of PART-145 certification: person in charge. Quality Manager. 2.- Nomination of other persons in accordance with a procedure acceptable to the JAA.

PART 145.35(h)

CERTIFYING STAFF
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1.- Records of each certifying staff member: at least name, date of birth, basic training, type training, continuation training, experience, qualifications relevant to the approval, scope of the authorisation, date of first issue of the authorisation, expire date of the authorisation (if appropriate), identification number of the authorisation. 2.- Organisation's quality department control of these records 3.- Access to the system: persons authorised kept to a minimu, ... 4.- Access by certifying person to his own records: any real case, Do they know they have access? 5.- Access to the JAA staff. 6.- Keeping of these records at least two years after the certifying person has ceased employment with the organisation. Copy of their record for certifying staff when leaving the organisation.. Real examples.

PART 145.35(i)

CERTIFYING STAFF
1.- Copy of authorisation provided to certifying staff (documented or electronic format).

PART 145.35(j)

CERTIFYING STAFF
1.- Provide the authorisation when requested in a reasonable time (24 hrs.) Authorised persons (official or business person or organisation with a valid reason for seeing the authorisation). (Ask the certifying staff). Real cases ?

PART 145.40(a)

EQUIPMENT, TOOLS AND MATERIAL


1. Disposal
(1)

of all tools, equipment and Pgina 14 de 34

material needed for: scope of approval, Capability List, (as specified in the approved data). 2. Control of tools and equipment that need servicing or calibration --> clearly identified and listed. Including personal tools. 3. Manufacture of tools and equipment: procedures included in MOE. 4. Base maintenance: sufficient aircraft access equipment and inspection platform/docking. 5. Necessary raw material and aircraft components readily available i.a. with manufacturer unless the organisation has an established spares provisioning procedure

(1) Availability of equipment and tools means permanent except in the case of any tool or equipment that is so rarely needed that its permanent availability is not necessary.

PART 145.40(b)

EQUIPMENT, TOOLS AND MATERIAL


1. Calibration and Control (2) of in use tools, equipment and test equipment. 2.1. Record of calibrations and standards used. 2.2. Register for all precision tooling and equipment. 3. Clear system of labelling to show when the next inspection or service or calibration is due or whether the item is unserviceable (where it may not be obvious). 4. Manufacturers' instructions or different time period --> Do Organisation results show that the used periods are appropriate in a particular case?
(2) procedure to inspect/service and, where appropriate, calibrate such items on a regular basis and indicate to users that the item is within any inspection or service or calibration time-limit.

PART 145.45(a) & (b)

MAINTENANCE DATA
1. Hold and use of applicable(1) current Pgina 15 de 34

maintenance data for the intended scope of work (including modifications and repairs)..
(1) Relevant to any aircraft, aircraft component or process specified in the approval class rating or associated capability list.

2. Airworthiness Directives, Operational directives, DGAC-E Info and DGAC Maintenance requirements, Maintenance and repair manuals, etc.; Recognized Applicable standards; Maintenance instructions produced by the organisation. 3. JAA Info: All Maintenance related PARTs & AMC, IEMs; Temporary Guidance leaflets; PART-145 listed Organisations. 4. For Class rating A --Aircraft: in addition to previous info. also (where published) appropriate sections of the operator's aircraft maintenance programme, aircraft maintenance manual, repair manual, supplementary structural inspection document, corrosion control document, SBs, SLs, SIs, modification leaflets, NDI manual, parts Catalogue, type certificate data sheet any other specific document issued by the type certificate or suppl. type certificate holder. Exception when operator or customer provided maintenance it is not necessary to hold them when the work order is completed other than 145.55(c). 5. For Class rating B --Engines/APUs: in addition to info. in number 3 & 4 above (where published) appropriate sections(1) of the engine/APU maintenance and repair manual, SBs, SLs, modification leaflets, NDI manual, parts catalogue, type certificate data sheet and any other specific document issued by the type certificate or suppl. type certificate holder. Exception when operator or customer provided maintenance it is not necessary to hold them when the work order is completed other than 145.55(c). 6. For Class rating C --Components: in addition to info. in number 3 & 4 above (where

(1) in relation to the maintenance work scope at each particular maintenance facility.

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published) appropriate sections(1) of the vendor maintenance and repair manual, SBs and SLs, plus any document issued by the type certificate holder as maintenance data. Exception when operator or customer provided maintenance it is not necessary to hold them when the work order is completed other than 145.55(c) 7. Only Class rating D--Specialised services: documents in number 3 plus the specialized service(s) process specification. Exception when operator or customer provided maintenance it is not necessary to hold them when the work order is completed other than 145.55(c)

(1) in relation to the maintenance work scope at each particular maintenance facility.

PART 145.45(c)

MAINTENANCE DATA
1. Procedure for Modification of Maintenance Data: equivalent or improved maintenance standards and type certificate holder informed. DO NOT: engineering design of repairs and modifications. Procedure should: a) address the need for a practical demonstration by the mechanic to the quality personnel of the proposed modified maintenance instruction. The quality personnel should approve or not the modified maintenance instruction and ensure the TC holder is informed. b) include a paper/electronic traceability of the complete proces from start to finish and ensure that the relevant maintenance instruction clearly identifies the modification.

Only used in the following circunstances: a.- Where the type certificate/suppl. type certificate holders original intent can be carried out in a more practical or more efficient manner. b.- Where the type certificate/suppl. type certificateholders original intent can not be acheved by following the maintenance instructions. For example, when a component cannot be replaced following the original maintenance instructions. c.- For the use of alternative tools/equipment.

PART 145.45(d)
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MAINTENANCE DATA
1. Major and Minor Repairs: organisations must be appropriately approved as required by PART-21 Subpart M to classify repairs and to approve minor repair design data except next paragraph. 2. Not for organisations that only carries out repairs i.a. with the approved type certificate holders published repair data or any other DGAC approved repair data. Procedure to ensure that appropriate action is taken in the case of damage assessment and the need to use only approved repair data.

Describe how repairs will be classified i.a. PART-21 Subpart M, how new repair design will be approved and how the organisation will ensure that only approved repair data is used in the implementation of a repair. Also elements of the next paragraph.

Describe actions to be taken when the need for damage assessment and/or repair action arises. (At minimum the need to assess damage against published approved repair data and the action to be taken if damage is beyond the limits or outside the scope of such data. Repair by replacement of damaged parts, requesting technical support from the type certificate holder or from an organisation approved i.a. PART-21 Subpart JA and finally DGAC approval of the particular repair data.

PART 145.45(e)

MAINTENANCE DATA
1. Provide a common workcard or worksheet system for use throughout relevant parts(1) of the organisation and either transcribe accurately the maintenance data or make precise reference to the particular maintenance task(s). Maybe computer generated and held on an electronic data base subject to both adequate safeguards against unauthorised alteration and a backup electronic data base which is updated within 24 hours of any entry made to the main electronic data base. 2. When maintenance service to an aircraft operator who require their workcard or worksheet system to be used then such docs. may be used ---> establish a procedure to ensure correct completion of the aircraft operators workcards/worksheets. 3. Complex maintenance tasks --> transcribed onto the workcards or worksheets and subdivided into clear stages to ensure a record of the accomplishment of the maintenance task. Need to differentiate and specify, when relevant, disassembly, accomplishment of task, reassembly and testing. 4. Lenghty tasks involving a succession of

(1) with regard to aircraft base maintenance, aircraft line maintenance, engine workshops, mechanical workshops and avionic workshops.

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personnel --> use supplementary workcards which was accomplished by each person.

PART 145.45(f) & (g)

MAINTENANCE DATA
1. All applicable maintenance data readily available for use when required by maintenance personnel. 2. Maintenance data and maintenance-related documents accessible to mechanics, supervisors and certifying staff in the maintenance area. (close proximity to the aircraft being maintained). 3. Computer terminals, microfiche readers/ printers available in a sufficient number or can these devices produce a sufficient number of copies. 4. Maintain a check that all amendments are being received. Procedure to monitor the amendment status of all data 5. Maintenance data provided/controlled by customers: must show that either it has a written confirmation that all such data is up to date or it has work orders specifying the amendment status of the data to be used or it can show that it is on the operator/customer data amendment list.

PART 145.50(a)

CERTIFICATION OF MAINTENANCE
1. Procedure for CRS at the completion of any package of maintenance(1) specified by the operator i.a. with such operator's responsibility in PART OPS 1(3).890. 2. Procedure for New defects or incomplete maintenance work orders identified during number 1 above--> aircraft operator agreement to rectify such defects or completing the Pgina 19 de 34
(1) any one or combination of the following elements; a check or inspection from the operator's programme, ADs, overhauls, repairs, modifications, component replacements and defect rectifications.

missing elements. If operator declines to have such maintenance, then 145.50(d) will apply. 3. Components maintained off the aircraft --> CRS to service for such maintenance and another CRS to being installed properly on the aircrat when such action occurs. 4. Procedures to issue the certificate of release to service at the completion of any defect rectification, whilst the aircraft operates flight between scheduled maintenance. 5. JAA Form One for components whilst off the aircraft. Component for use by the organisation, may not be necessary depending upon the organisations' internal release procedures defined in MOE.

PART 145.50(b)

CERTIFICATION OF MAINTENANCE
1. Certificate of release statement(1) acc. to AMC 145.50(b)1 2. Relation to the task in the manufacturer's or PART-OPS operator's instruction or the aircraft maintenance programme (may cross-refer to a manufacturer's/operator's instruction in a maintenance manual, SB, etc... 3. Approval reference of the organization and identity of certifying staff. 4. Date maintenance was carried out. 5. Procedures to document the calendar time/flying hours/cycles/engine cycles relative to any life or overhaul limitation. 6. Extensive maintenance: summarise the maintenance so long as there is a unique crossrererence to the work-pack containing full details of maintenance carried out. Dimensional information should be retained in the work-pack record. Pgina 20 de 34
(1) The CRS statement in block 19 of the JAA Form One is slightly at variance with AMC 145.50(b)1 in that it refers to information in particular boxes on the Form.

7. Certificates of release to service signed with the normal signature or computer release to service. [stamp is optional] 8. If computer release to service --> Only the particular person can electronically issue the CRS. Magnetic or optical personal card in conjunction with a personal identity number (PIN) known only to the individual which is keyed into the computer.

PART 145.50(c)

CERTIFICATION OF MAINTENANCE
1. Does the Maintenance Organisation have a procedure to ensure that all components which have to be installed on the aircraft have been subject to the alteration required at the date of installation and that all AD`s are complied with? Used components prior to PART-145 --> 1 Jan 2000 2. Procedure: issue JAA Form One for components last maintained prior to PART-145.

PART 145.50(d)

CERTIFICATION OF MAINTENANCE
1. Procedure when unable(1) to complete all maintenance required by the customer (being the aircraft operator) within the aircraft operators limitations --> entered in the aircraft CRS before issue of such certificate. (1) Unable means that the maintenance required by the operator could not be completed due either to running out of available maintenance downtime for the scheduled check or by virtue of the condition of the aircraft requiring additional maintenance downtime. Check for real examples. 2. Operator informed in case where full compliance with 145.50(a) cannot be achieved within the operators limitations. If the operator agrees to the deferment of full compliance, then the CRS may be issued subject to details of the deferment, including the operator's authority(2), Pgina 21 de 34

being endorsed on the certificate. Check for real examples. 3. Procedure: draw attention to the fact that 145.50(a) does not normally permit the issue of a CRS in the case of non-compliance. It should state what action the mechanic, supervisor and certifying staff should take to bring the matter to the attention of the relevant department or person responsible for coordination with the ops (discuss and solve with the ops). In addition, the appropriate 145.30(a) person(s) should be kept informed in writing of such possible non-compliance situations.

(2)

Whether or not the operator does have authority to defer maintenance is an issue between the ops and its authority. In case of doubt --> PART145 should inform its DGAC, of such doubt, before issue of the CRS. This will allow DGAC to investigate the matter with the ops NAA.

PART 145.50(e)

CERTIFICATION OF MAINTENANCE
1. Aircraft grounded at a location other than the main line station or main base due to nonavailability of a component with the appropriate release certificate --> temporary fit a component without the appropriate CRS for 30 flight hours max. or until the aircraft first returns to the main line station or main base, whichever is sooner, subject to the ops agreement and said component having a suituable serviceable tag(1) but otherwise in compliance with all other PART-OPS 1 or 3 Subpart M and PART-145 req's.(2) Check real examples.

(1) a tag which clearly states that the aircraft component is serviceable; that clearly specifies the organisation releasing the component together with details of the JAA-NAA or non-JAA NAA under whose approval the organisation works including the approval or authorisation reference. (2) making an appropriate entry in the aircraft technical log, checking for compliance with type design standards, modifications, repairs, ADs, life limitations and condition of the component plus information on where, when and why the aircraft was grounded.

PART 145.50(f)

CERTIFICATION OF MAINTENANCE
1. NO CRS when: Non-compliance know to the PART145 organisation which could hazard flight safety. Examples: significant cracking, deformation, corrosion or failure of primary structure, any evidence of burning, electrical Check Real Examples. arcing,, significant hydraulic fluid or fuel leakage and any emergency system or total system failure. An AD overdue. Pgina 22 de 34

PART 145.55(a)

MAINTENANCE RECORDS
1. Record all details of work carried out: unambiguous requirements for the execution and keeping of maintenance records.
Properly executed an retained records --> information essential in controlling unscheduled and scheduled maintenance, and trouble shooting to eliminate the need for re-inspection and rework to establish airworthiness.

2. Executed: as a minimum all necessary to prove all requirements have been met, including sub-contractor's release documents. Prime objective: secure and easily retrievable records with comprehensive and legible contents Aircraft records should contain basic details of all serialised aircraft components and all other significant components installed, to ensure traceability to such installed component documentation an associated PART145.45 maintenance data. 3. Gas turbine engines assembled from modules --> Total time in service and maintenance records for each module. Kept with the module and should show compliance with any mandatory requirements pertaining to that module. 4. Reconstruction of lost maintenance records: 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 still incomplete --> statement in the new record describing the loss and establishing the time in service based on the research and the best estimate time in service and summitted to the DGAC for acceptance. Real examples. 5. Paper system: robust material which can withstand normal handling and filing. It should remain legible throught the required retention period.
Additional maintenance may be required.

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6. Computer systems: Backup system updated at least within 24 hours of any maintenance.
Computer systems: control maintenance and/or record details of work carried out.

7. Computer systems: Each terminal --> programme safeguards against the ability of unauthorized personnel to alter the database
Computer systems: control maintenance and/or record details of work carried out

PART 145.55(b)

MAINTENANCE RECORDS
1. Procedure which describes the delivery to the operator of the CRS, together with a copy of any specific approved repair/modification data.

PART 145.55(c)

MAINTENANCE RECORDS
1. Provisions to retain a copy of all detailed maintenance records and any associated maintenance data for two years from the date it was released. Check for real examples. 2. Procedures of other required storage times for Maintenance Organisations, due to the contract with a PART-OPS holder and the requirement to hold operational record, determined in the MOE. Retention period would be PART-OPS 1(3) Subpart M. 3. Records stored in a safe way with regard to fire, flood and theft. 4. Computer backup discs, tapes, etc. stored in a different location from that containing the working discs, tapes, etc., in an environment that ensures they remain in good condition. 5. Provisions for maintenance records of last two years (if the PART145 Organization terminates operation): last owner/customer or contact DGAC.

PART 145.60(a)
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OCCURRENCE REPORTING
1. MOE provisions for the duty to report unairworthy conditions (aircraft or aircraft components) to the DGAC and aircraft TC holder . 2. Are the persons responsible for these reports within the Maintenance Organisation clearly identified ?
Serious cracks, permanent deformation, burning or serious corrosion of struture found during scheduled maintenance of the aircraft or engine or propeller or helicopter rotor system. Failure of any emergency system during scheduled testing. Some ADs actions require to report conditions.

PART 145.60(b)

OCCURRENCE REPORTING
1. Persons responsible to report and Forms in accordance with the DGAC. regulations (IC`s), included in MOE.

PART 145.60(c)

OCCURRENCE REPORTING
1. Procedure for the contracted Maintenance Organisation for reporting unairworthy conditions to the PART-OPS operator.

PART 145.60(d)

OCCURRENCE REPORTING
1. Time limit for reporting as soon as practicable but in any case within 3 days.

PART 145.65(a)

MAINTENANCE PROCEDURES AND QUALITY SYSTEM


1. Maintenance Organisation Exposition must include a quality policy. Example: IEM 145.70(a) (10)

PART 145.65(b)

MAINTENANCE PROCEDURES AND QUALITY SYSTEM


1. Maintenance Organisation Exposition with the maintenance procedures: it should address 145.25 to 145.95. Appdx. 2 of PART145: example of typical procedures. 2. Procedures: provision and control of Pgina 25 de 34

specialised services. 3. Subcontracting procedures [(Ref.: Appendix 6 ``Non-PART-145 Organisations Working Under the Quality System of a PART-145 Approved Maintenance Organisation'') 4. Aircraft line and base maintenance: procedures to ensure that no one person be required to carry out and inspect in relation to a maintenance task involving some element of disassembly/reassembly of several aircraft components of the same type fitted to more than one system on the same aircraft during a particular maintenance check. When only one person --> workcard should include an additional stage for re-inspection, after completion of all the same tasks. 5. Amendment procedures for the change of the maintenance organisation exposition

PART 145.65 (c) 1

MAINTENANCE PROCEDURES AND QUALITY SYSTEM


1. Maintenance Organisation quality system, including independent audits. 2. .Audit Plan : time schedule, content of the audits to be carried out, random audits on a sample basis when maintenance is being carried out (at night, etc.), line stations, Not each procedure against each product line when it is common, except if findings have been identified in that procedure of one product line --> other product lines until the findings have been rectified. 3. Maintenance procedures subject to annual inspection in relation to each product model (Class rating of Appendix 1). 4. Product audits (it could be combined with procedure audits).
Audits: routine sample checks of all aspects of PART-145 organisation's ability to carry out all maintenance to the required standards and includes some product sampling (end result of process). It should include a percentage of random audits carried out on a sample basis when maintenance is being carried out (during night-> organisations working at night )

Example: an organisation with a capability to maintain aircraft, engines, brakes and autopilots would need 4 complete audit sample checks each year. Appendix 5 --> Examples of audit subjects and plans.

Combined product audits with procedure audits by selecting a specific product example (aircraft or engine or instrument) and sample checking all the procedures and requirements associated with the specific product example. Sample check: to witness any relevant testing and visually inspect the product and associated documentation. Not disassembly unless big findings.

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5. Smallest organisations (1): the independent audit part of the quality system may be contracted to another PART-145 approved org. or a person with appropriate technical knowledge and proven satisfactory audit experience acceptable to the JAA full member Authority. Audit being carried out twice in every 12 month 6. Line stations: integrated into the system and include a plan to audit each listed line station at a frequency consistent with the extend of flight activity at the particular station. (24 months periods except increase i.acc. paragraph 7) 7 Increase any audit time periods up to 100%: there is no safety related findings and subject to being satisfied that the organisation has a good record of rectifying findings in a timely manner. 8 System to issue audit reports : what was checked and the resulting findings against applicable requirements, procedures and products. sent to relevant departments, target date. 9. Independence Audits: personnel not responsible for the function, procedure or products being checked. . 10. Large organisation (more than 500 maint. staff) --> dedicated quality audit group whose sole function is to conduct audits, raise finding reports and follow up to check that finding are rectified. 11. Medium sized (less than 500) --> use competent personnel from one section/department not responsible for the production function, procedure or product to audit the section/department that is responsible subject to the overall planning and implementation being under the control of the quality manager. 12. Small organisations (maximum of 10 maint. staff) --> may contract the independent audit element of the quality system to another

(1) Maximum of 10 personnel actively engaged in maintenance.

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PART145 approved maintenance organisation or a competent person acceptable to the DGAC.

PART 145.65(c) 2

MAINTENANCE PROCEDURES AND QUALITY SYSTEM


1. Quality Feedback System: reporting to the persons or group of persons in 145.30(a) and ultimately to the accountable manager. 2. Management control follow up system may not be contracted to outside persons. 3. All findings resulting from the independent quality audits are properly investigated. Proper corrective actions. 4. All findings resulting from the independent quality audits are corrected in a timely manner. Timely corrective actions. Reports sent to the relevant departments for rectification action giving target rectification dates. Rectification dates should be discussed with such departments before the quality department or nominated quality auditor confirms such dates in the report. 5. Relevant departments are required to rectify findings and inform the quality department or nominated quality auditor of such rectification.. 6. Enable accountable manager to be kept informed of any safety issues and the extent of compliance with PART-145. 7. Regular meetings of Acc. Mgr. with staff to check progress on rectification (large organisations QM take this roll, based on the fact that the Acc. Mgr. meeting twice a year with senior staff). 8.- )Records pertaining quality audit and the quality feedback system ==> Retention period: Two years after the date of clearance of the finding to which they refer or to suppor changes to the audit time periods, whichever is the longer.

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PART 145.70(a)

MAINTENANCE ORGANISATION EXPOSITION


1. Management Part of the MOE:
a) statement signed by the accountable manager. [IEM 145.70 (a) 9] If Acc. Mgr is not chief executive officer --> countersign the statement. b) Quality Policy [IEM 145.70 (a) 10] c) titles and names of the senior persons. d) duties and responsibilities of the senior persons, including matters on which they may deal directly with the DGAC. e) organisation chart showing associated chains of responsibility of the senior person(s). f) list of certifying staff g) general description of manpower resources. h) general description of the facilities located at each address specified in the approval certificate. i) specification of the scope of work relevant to the extent of approval. j) notification procedure acc. to PART 145.85 for organisation changes. k) MOE amendment procedure. One document and available to senior persons 145.30(a) who should be familiar with it. 2. Working Procedures: a) PART 145.25 facility requirements b) PART 145.30 personnel requirements c) PART 145.35 record of certifying staff d) PART 145.40 equipment, tools and material Pgina 29 de 34

e) PART 145.45 Airworthiness data f) PART 145.50 certification of maintenance g) PART 145.55 maintenance records h) PART 145.60 reporting of unairworthy conditions i) PART 145.65 maintenance procedures and quality system j) PART 145.70 maintenance organisation exposition k) PART 145.75 privileges of the approved maintenance organisation 2. Working Procedures: (CONT.) l) PART 145.80 limitations of the approved maintenance organisation m) PART 145.85 changes to organisation n) PART 145.90 Continued validity of appr.(*) (*) Continued Validity: no expiration date; neither surrendered, superseded, suspended, revoked. o) PART 145.95 equivalent safety case (All them may be kept as separate documents) 3. Lists : a) List of PART-OPS operators to which the Maintenance Organisation provides an aircraft maintenance service b) List of organisations under Quality Control of PART-145 organisation [PART145.75(b)] c) List of line stations [PART 145.75(d)] d) List of contracted PART-145 approved organisations if appropriate. 4. The following items must be dealt with during the audits: a) personnel familiarisation with those parts of the manuals which are relevant to the maintenance work they carried out b) who should amend the manual particularly where there are several parts. c) Quality manager responsible for the amendment and submission of the MOE, including associated procedures manuals. d) Is it agreed - if appropriate - by the DGAC. that some defined classes of amendments may be incorporated without prior DGAC-E. approval ? Pgina 30 de 34

5. Organisation approved against any other PART (i.e. PART OPS) ---> A supplement covering the differences will suffice to meet the requs. except that the supplement must have an index showing where those parts missing fro the supplement are covered.

PART 145.70(b)

MAINTENANCE ORGANISATION EXPOSITION


1.Possible separate documents or separate electronic data files: a).- List of Certifying Staff b).- Maintenance procedures and Lists (Subparagraphs 2 and 3, in previous paragraph). Check for clear cross reference in management part of MOE.

PART 145.70(c)

MAINTENANCE ORGANISATION EXPOSITION


1. Maintenance Organisation Exposition approval by the DGAC-E. / Knowledge of the status by the organisation.

PART 145.75 (a)

PRIVILEGES OF THE APPROVED MAINTENANCE ORGANISATION


1.- Maintenance locations identified in the approval and /or in the approved MOE.

PART 145.75 (b)

PRIVILEGES OF THE APPROVED MAINTENANCE ORGANISATION


1.- Organisations under the Quality Control of this PART-145 Organisation: procedures. Pgina 31 de 34

PART 145.75 (c)

PRIVILEGES OF THE APPROVED MAINTENANCE ORGANISATION


1.- Procedures for occasional line maintenance at any location as per PART-145.75(c). 2.- Procedures for occasional maintenance arising from the unserviceability of the A/C. [PART 145.75(c)]

PART 145.75 (d)

PRIVILEGES OF THE APPROVED MAINTENANCE ORGANISATION


1.- Line maintenance stations: check works done versus the capability. (Other than main location). 2.- Line maintenance procedures.

PART 145.75 (e)

PRIVILEGES OF THE APPROVED MAINTENANCE ORGANISATION


1.- See examples of CRS's of work performed as per (a), (b), (c) and/or (d)

PART 145.80

LIMITATIONS ON THE APPROVED MAINTENANCE ORGANISATION


All necessary facilities, equipment, tooling, material, maintenance data and Certifying staff. Check all Aircraft Types, Engine Types & C Ratings.

Temporarily not hold all the necessary tools, equipment for an aircraft type or variant specified in the approval. Not need to amend the approval to delete the aircraft type or variants on the basis that it is a temporary situation and there is a commitment from the organisation to re-acquire tools, equipment etc. before maintenance on the type may recommence.

PART 145.85 (a)

CHANGES TO THE APPROVED MAINTENANCE ORGANISATION


1. Confirm No Changes without notification Pgina 32 de 34

(before such changes take place): - name - locations - additional locations - accountable manager - senior persons - facilities, equipment, tools, material, procedures, work scope and,certifying staff that could affect the approval. - This paragraph is to enable the PART-145 organisation to remain approved if agreed by DGAC during negotiations about any of the specified changes. Without this paragraph the approval would automatically be suspended in all cases. - Exception are the case of proposed changes in personnel not known to the management beforehand.

PART 145.85 (b)

CHANGES TO THE APPROVED MAINTENANCE ORGANISATION


1.- DGAC: Conditions under which the PART145 Organisation may operate during such changes.

PART 145.90

CONTINUED VALIDITY OF APPROVAL


Approvals without expiration date, surrended, superseded, suspended, revoked. or

a.- Organisation remaining in compliance with PART-145 b.- access granted to JAA Authority, c.- payment of charges prescribed.

PART 145.95(a)

EQUIVALENT SAFETY CASES


Is it understood by the organisation ? 1.- Exemption: situation not envisaged by a PART 145 requirement and subject to compliance with any supplementary conditions. Such conditions must be agreed by the JAA full member Authorities to ensure continued recognition of the approval.

When equivalent safety case has been accepted by the JAA full member Authorities --> amended PART's or AMC's or initially as maintenance TGL's.

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PART 145.95(b)

EQUIVALENT SAFETY CASES


Is it understood by the organisation ? 1.- Exception: the DGAC may exempt an organisation from a requirement in PART 145 on an individual case by case permission basis only subject to compliance with any supplementary condition(s) necessary to ensure equivalent safety.

PART 145.100

REVOCATION, SUSPENSION, LIMITATION OR REFUSAL TO RENEW THE PART-145 APPROVAL CERTIFICATE


a.- Does the Organisation knows their rights with respect to Revocation, suspension, limitation and refusal ? (described in JAA Administration & Guidance Material).. b.- Safe operation of an aircraft could be adversely affected: In addition to paragraph (a) --> Provisionally suspend, in part or in whole, the PART-145 approval certificate without prior notice until the sub-paragraph (a) procedure is complete..

28 days notice to the holder in writing of its intention so to do and the reasons for its proposal and must offer the holder an opportunity to make representations and said Authority will consider those representations.

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