Initial Certification Process – For E.U.-Based Maintenance Organizations
Applicant Responsibility: To apply for a 14 Code of Federal Regulations (CFR) part 145 repair station certificate under the provisions of the Bilateral Agreement Maintenance Annex, an applicant AMO must:
Be located in the one of the EU Member States & Hold EASA Part-145 approval.
Demonstrate a need to maintain or alter U.S.-registered aircraft and / or aeronautical products being installed on U.S.-registered aircraft.
The applicant must contact the Airworthiness Authority (AA) of the Member State in which the organization’s principal place of business is located.
NOTE: The AA should ensure that the AMO does not have any outstanding findings of non-compliance from AA oversight audits.
The Applicant Shall
Submit an FAA Supplement to the EASA Part-145 MOE.
Provide the AA with a written statement showing the necessity of the certificate, hereinafter referred to as “Statement of Need.”
Statement of Need
In order to qualify for an FAA-approved AMO located in an EU Member State, an AMO must have previously obtained an EASA approval.
The AMO must submit evidence of a need to maintain or alter U.S.-registered aircraft and parts.
This evidence may be in the form of a Letter of Intent (LOI), work order, or contract with details of the relevant customer.
A relevant customer may be a U.S.-based repair station; or a U.S. operator, distributor, or lessor.
Upon receipt of the Pre-application Statement of Intent (FAA Form 8400-6) and the SAS Vitals Information addressed in Appendix 4 of this section
Once the package is complete, the AA should forward a copy to the supervising FAA office.
FAA Action to allocate the pre-certification and final certification numbers to be forwarded to the AA for distribution. (forward info to the applicant)
Line stations must be under the oversight of an AA that is part of the Agreement.
Note – EASA uses the term line stations; the FAA uses the term Line Maintenance Authorization in regard to 14 CFR part 145.
Applicant Responsibility
The applicant must submit to the AA the formal application package, which contains the following.
FAA Form 8310-3, Application for Repair Station Certificate and/or Rating containing the list of maintenance functions
A statement of need. The applicant should be advised that the FAA requires an updated document showing the applicant’s continuing need at each renewal.
Dangerous Goods Training Requirement
A letter certifying that its employees, contractors, and subcontractors have been trained in the transportation of dangerous goods in accordance with ICAO standards.
This requirement is applicable if the AMO is involved with the transport of dangerous goods, including shipping and receiving of such items.
If AMO is involved in the loading of dangerous goods on a U.S. air carrier’s aircraft, the AMO’s employees must be trained in accordance with the air carrier’s hazardous materials training program.
The addresses of all additional fixed locations located within an EU Member State (A repair station may have additional fixed locations (facilities) without certificating each facility as a stand-alone or satellite repair station.)
The addresses of line station’s authorizations, if any, and the name of the air carrier or operator of the U.S.-registered aircraft.
NOTE: The FAA will only recognize line stations that are under the direct Surveillance of an AA of the Agreement and holding an EASA line station approval, except those located in the United States.
Copy of EASA Form 3 approval certificate, including the scope of approval.
Airworthiness Authority Guidance
The AA should review the contents for correctness.
This should include a review of the proposed FAA Supplement in comparison with the sample FAA Supplement in Appendix 1.
The supplement must be customized to reflect the AMO’s operations and procedures but still must contain the same information as the example supplement paragraphs.
If the information that the AMO submits is acceptable, the AA should conduct an oversight audit for compliance with EASA requirements and FAA Special Conditions, using Audit Report 2
EASA Compliance
If the AMO has successfully completed an AA oversight audit within the preceding 180 days / 6 months period of the AA’s recommendation to the FAA for certification, the AA should not have to conduct a review for compliance with EASA requirements.
FAA Compliance
The AA is to conduct an oversight audit for compliance with FAA Special Conditions and the FAA supplement regardless of whether an audit for compliance with EASA requirements has been successfully completed within 180 days / 6-month period.
Where applicable, the AA should notify the AMO of the required fee for the performance of this audit. The AMO should direct all questions regarding these fees to the AA.
Compliance Timeframe
If the AA discovers deficiencies in an AMO’s application package or after conducting an oversight audit, the AA may process the finding in accordance with EASA Part-145, Section B, requirements, but the period for corrective action shall not exceed 6 months.
If the applicant fails to correct the deficiencies within the timeframe the AA allowed, the AA should terminate the application process and notify the FAA.
In the event of unusual circumstances, the AA should notify the FAA, and the FAA may agree to extend the period upon mutual agreement for a reasonable period of time, if the applicant demonstrates an ability and willingness to correct the noted deficiencies.
Corrective action must be taken, the applicant should notify the AA in writing when all deficiencies have been corrected.
The AA must retain a copy of the initial certification package, which must be available to the FAA on request.
The AA will send the following completed documents to the FAA.
Audit Report 2
Note each time Audit Report 2 is revised, the manager of the AA surveillance department will issue a new certifying statement to the FAA.
The FAA Coordinator International Field Office (IFO) must keep a current copy of this letter in the AA file.
The appropriate recommending inspector/surveyor official will complete blocks 6, 7, 8 and 9 of FAA Form 8310-3. (This method approves the list of functions to be subcontracted/contracted on behalf of the FAA.)
A copy of the completed Audit Report 2 for the applicant AMO. (Also include a separate Audit Report 2 and a signed recommendation for each additional fixed location and line station that will utilize the 14 CFR part 145 privileges.
The addresses of line station’s authorizations, if any, and the name of the air carrier or operator of the U.S.-registered aircraft.
NOTE: If there are no changes to the letter content, then update the date of the letter. If there are changes, update both the text and the date.
A copy of the AMO’s AA Certificate and scope of approval, EASA Form 3.
The AA is required to retain one current copy of the FAA Supplement to the MOE in the English Language and make that supplement available to the FAA on request
FAA Action
The FAA will review the documents to ensure the package is complete.
During initial certification, there should be no open findings on Audit Report 2 or on any of the documents submitted to the FAA. However, the FAA recognizes that Minor discrepancies may occasionally be noted. These minor discrepancies must be discussed with the AA, but should not delay the issuance of the FAA certificate.
NOTE: When the applicant’s FAA Supplement to the MOE is included as a supplement chapter to the MOE (Part 7), and the MOE has been approved by the AA, the FAA considers the manual acceptable in accordance with 14 CFR part 145.
NOTE: The AA is not required to provide to the FAA the MOE or FAA Supplement as a part of a certification package.
The FAA Airworthiness Safety Inspector (ASI) must update the information contained in the Safety Assurance System SAS Vitals Information.
At this time the FAA ASI shall verify if there are any special authorizations and limitations (such as electronic record keeping system).
The FAA will also include a cover letter with instructions for an appropriate official at the AMO to sign and return a copy of the Operations Specifications to the FAA and AA by email as a PDF attachment.
The Air Agency certificate will list the FAA rating.
The FAA OpSpecs will list the EASA certificate number (Form 3) and the current revision and date.
The AMO will sign and date the operation specifications and return a signed copy to the FAA and AA.
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