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This article considers the process by which Pilots may certify maintenance within a Part M and Part 145 environment.
There is an added layer of complexity in respect that some groups of aircraft for example Aerial Work Aircraft are not in fact covered completely by EASA regulations.In this respect it falls on the National Authority to make appropriate determinations, however it is not within their (The National Authority of the State of the Regulator) power to allow deviations on Non-Annex 2 Aircraft which are less stringent or onerous than those which are issued through the EASA regulatory framework.
Such power to deviate from EASA requirements is no longer vested in the National Authority with the Adoption by the EU of 2002/ 1592 which was superseded by 2008/216.
There are basically 2 different scenarios to consider in respect of Pilot Certification of Maintenance :
The first is in respect of Non commercial aviation, which depending on the weight of the aircraft may be performed by a Part M subpart F organization, providing the aircraft is below 2730 Kg in basic weight.
The details are covered in M.A.801 Aircraft certificate of release to service which refers the reader to M.A.803 Pilot-owner authorization.
A detailed list of the tasks which may be performed and certified as pilot maintenance shall be included in the MP (Maintenance Program) for the applicable aircraft. The MP is approved by the regulator of the state of the operator. Reference should be made to M.A. 302.
Note – In the case of pilot certified maintenance this is limited to non complex tasks as detailed in Part M Appendix VIII – Limited Pilot-Owner Maintenance.
In respect of Competence and responsibility, it is required that the Pilot-owner is always responsible for any maintenance that he performs. In addition to familiarize themselves with the standard maintenance practices for their aircraft and with the aircraft maintenance programme.
If the Pilot-owner is not competent for the task to be carried out, the task cannot be released by the Pilot-owner.
Note also that for aircraft above 2730 Kg it is not possible for Pilots to sign any maintenance tasks on these aircraft. – essentially it is a function of managing and maintaining competence as may be understood when considering the part 145 environment.
The second option concerns the certification of pilots in a Part 145 environment.
Because Pilot Certification of Maintenance in a CAT (Commercial Air Transport Environment) is managed by the Part 145 organization there is no criteria placed on the aircraft weight rather it is a function of the training and management of competencies relating to the particular tasks.
Reference to the following AMC 145.A.30 (j)(4) shows that Pilots appropriately qualified my certify commercial air transport aircraft by holding a limited certification authorization which is subject to the maintenance organisation exposition containing procedures to address the personnel requirements of 145.A.30 (e) and associated AMC and guidance material.
Minimum procedures would address.
Completion of adequate maintenance airworthiness regulation training.
Completion of adequate task training for the specific task on the aircraft.
Completion of the procedural training as specified in Part-145.
Typical Pilot Certification of Maintenance tasks that may be certified and/or carried out :
1/ Replacement of lights, filaments and flash tubes. (Internal and External)
2/ Closing of cowlings and refitment of quick access inspection panels.
3/ Role changes e.g. stretcher fit, dual controls, FLIR, doors, photographic equipment etc.
4/ Inspection for and removal of de-icing/anti-icing fluid residues, including removal/ closure of panels, cowls or covers that are easily accessible but not requiring the use of special tools.
5/ Any check / replacement involving simple techniques consistent with this AMC
and as agreed by the competent authority.
6/ Replacement of wheel assemblies.
7/ Replacement of simple emergency equipment that is easily accessible.
8/ Replacement of ovens, boilers and beverage makers.
9/ Replacement of passenger and cabin crew seats, seat belts and harnesses.
10/ Simple replacement of overhead storage compartment doors and cabin furnishing items.
11/ Replacement of static wicks.
12/ Replacement of aircraft main and APU aircraft batteries.
13/ Replacement of inflight entertainment system components but excluding PA
14/ The de-activation only of sub-systems and aircraft components as permitted by the operator’s minimum equipment list where such de-activation is agreed by the competent authority as a simple task.
15/ Re-setting of tripped circuit breakers under the guidance of maintenance control.
Any other simple task as agreed by the competent authority for a particular aircraft type only where it is agreed that the task is simple.
Notes:
There are two notes to be considered in the context of Pilot Certification of Maintenance
The first is the Competent authority must approve the entire process the second is that the authorization should have a finite life of twelve months subject to satisfactory re-current training on the applicable aircraft type.
Understanding Corporate Responsibility and Corporate Exposure
The organization may not deviate from IR (Implementing Rules) and the Competent authority has no power to grant this, means under existing legislation it is not legally possible for a pilot to certify under part M aircraft above 2730 Kg using Subpart H CRS.
In the context of Part 145 Pilot Certification there is considerable more scope as the AMC may be adjusted with permission from the regulatory authority.
In the event that an illegal ( IE outside of the EASA IR – Implementing Rule, legal framework) CRS is issued by the pilot, then it renders the CRS invalid and as a consequence the Certificate of Airworthiness is also compromised.
In the event that an insurance claim was ever made in respect of the aircraft, the company may well find it has broken the terms of its corporate responsibility and the insurance company may refuse to pay out.
The message is clear – in respect of Pilot Certification of Maintenance (and not only of course) not following EASA requirements ultimately is a high risk corporate strategy.
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This Article was written by Steven Bentley on behalf of Sofema Aviation Services
Comments and response always very welcome please email team@sassofia.com
