Concerning the Provision of Continuing Airworthiness Records EASA (Forthcoming ref CRD -Decision 2014-04)

Comment by Sofema Aviation Services

Note – In all cases concerning Aircraft Technical Records EASA requirements should be considered as the minimum requirement to demonstrate compliance with regulatory requirements.

In many cases, there are more onerous requirements which should be addressed as part of Leasing Obligations.

Therefore in all cases to ensure there is adequate awareness within both Maintenance Planning & Technical Records Departments in particular related to oversight concerning the leasing agreement management & return conditions obligations.

Regarding the Criteria by which Aircraft Technical Records may be recorded into an IT system (Ref AMC M.A.305(e) Aircraft continuing-airworthiness record system)

(a) The information that constitutes the aircraft continuing-airworthiness records may be entered in an information technology (IT) system and/or documents equivalent in scope and detail.

IT systems acceptable for supporting the aircraft continuing-airworthiness records should:

(1) include functions so that search of data and production of status is possible;

(2) allow a transfer of the aircraft continuing-airworthiness records data from one system to another using an industry-wide/worldwide data format or allow printing information;

(3) contain safeguards which prevent unauthorised personnel from altering data; and

(4) ensure the integrity of the data, including traceability of amendments.

Regarding the process to include CRS within the record system (Ref AMC M.A.305(a) Aircraft continuing-airworthiness record system)

(a) The inclusion of the CRS in the aircraft continuing-airworthiness record system means that the date at which the maintenance was performed, and/or that any applicable parameter, including a unique reference to the CRS, should be processed in the record system.

(b) For components with airworthiness limitations, this information should be found on the authorised release certificate (EASA Form 1 or equivalent).

For LLPs, some relevant information required by M.A.305 may need to be introduced into the in-service history records.

Regarding the Managing of Engine & Propeller Module Records (AMC M.A.305(b)(1) Aircraft continuing-airworthiness record system

(a) Certain gas turbine engines and propellers are assembled from modules, and a record of the total life accumulated in service for the complete engine or propeller may not be kept.

When owners and operators wish to take advantage of the modular design, then the total life accumulated in service for each module, as well as in-service history, if applicable, and detailed maintenance records for each module should be maintained.

The continuing-airworthiness records, as specified, should be kept with the module and show compliance with any mandatory requirements pertaining to that module.

(b) The recording of in-service life accumulation may be necessary also in other measurement units to ensure the continuing airworthiness of the aircraft. For example, a mandatory life limitation measured in cycles of auxiliary power unit (APU) usage may apply to some rotating parts. In such a case, APU cycles need to be recorded.

Regarding the Status of Modification & Repairs – Within the Aircraft continuing-airworthiness record system (AMC M.A.305(c)(2))

(a) ‘Status of current modifications and repairs’ – means a list, compiled at aircraft level, of modifications and repairs currently embodied.

It should include the identification of the aircraft, engine(s) or propeller(s), as appropriate, and the date of the CRS when the modification or repair was accomplished.

Where a modification or repair creates the need for the accomplishment of scheduled maintenance tasks, the reference to the applicable tasks should be added to the AMP. (For example in relation to repetitive Inspections)

The status should include the reference to the data in accordance with M.A.304, which provides the accomplishment procedure for the modification or repair.

It should also specify which part of a multipart modification or repair has been accomplished, as well as the method of compliance, where a choice is available in the data.

(b) In addition to the previous applicable information, with respect to structure, the status of the current repairs should contain the description of the repair (e.g. doubler, blend, crack, dent, etc.), its location (e.g. reference to stringers, frames, etc.) and its dimensions.

Note – In the case of blend-out repairs, the remaining material should be recorded as well.

Note – GM M.A.305(c)(2) Aircraft continuing-airworthiness record system

(a) The status of modifications and repairs may include the impact of a specific modification or repair on:

(1) embodiment instructions;

(2) mass and balance change data;

(3) maintenance and repair manual supplements;

(4) maintenance programme and instructions for continuing airworthiness; and/or

(5) aircraft flight manual (AFM) supplements.

Regarding the Status of Loadable Software (AMC M.A.305(c)(2))

(b) When aircraft require a specific loadable software aircraft part (LSAP) configuration in order to operate correctly, a specific listing with this information may be necessary as well.

(c) The status of modifications should be sufficiently detailed to identify any installed loadable software aircraft part (LSAP) used for operating or controlling the aircraft, the part number of which evolves independently of its associated aircraft hardware component, as identified in the maintenance data of the relevant design approval holders (DAHs).

Other loadable software parts, such as navigational databases or entertainment systems, are not considered under this recording requirement.

Concerning life-limited parts (LLPs) and time-controlled components (TCCs); ((Forthcoming ref CRD-Decision 2014-04)

The following which for now can be considered as “best practice” should be adopted and formalised within the near future.

Mandatory instructions (and associated airworthiness limitation) in accordance with Part-21 affecting a component – Permanent removal (replacement):

LLP e.g.: engine high-pressure turbine (HPT) disc, landing gear sliding tube

— Current status (M.A.305(d)(1));

— In-service history record (M.A.305(e)(3)(i));

— EASA Form 1 and detailed maintenance records for last scheduled maintenance and subsequent unscheduled maintenance (M.A.305(e)(3)(ii)); and

— EASA Form 1 and detailed maintenance records for modifications and repairs (M.A.305(e)(2)(ii)).

Mandatory instructions (and associated airworthiness limitation) in accordance with Part-21 affecting a component:

Periodic removal for maintenance in an appropriate approved workshop, e.g.: an overhaul of horizontal stabilizer actuator or of landing gear; and/or replacement of U-joints (of a gearbox).

TCC e.g.: horizontal stabiliser actuator, landing gear gearbox

Current status (M.A.305(d)(2));

— EASA Form 1 and detailed maintenance records for last scheduled maintenance and subsequent unscheduled maintenance (M.A.305(e)(3)(ii)); and

— EASA Form 1 and detailed maintenance records for modifications and repairs (M.A.305(e)(2)(ii)).

LLP -

— Current status (M.A.305(d)(1));

— In-service history record (M.A.305(e)(3)(i));

— EASA Form 1 and detailed maintenance records for the last scheduled maintenance and subsequent unscheduled maintenance (M.A.305(e)(3)(ii)), including modifications and repairs (M.A.305(e)(2)(ii)).

TCC – Hard Time

— Current status (M.A.305(d)(2));

— EASA Form 1 and detailed maintenance records for the last scheduled maintenance and subsequent unscheduled maintenance (M.A.305(e)(3)(ii)), including modifications and repairs (M.A.305(e)(2)(ii)).

On-condition

— Current status (M.A.305(d)(2)); and

— EASA Form 1 and detailed maintenance records for the last scheduled maintenance and subsequent unscheduled maintenance (M.A.305(e)(3)(ii)).

Note – If the task is controlled at aircraft level, the above information may be already contained in the records related to the AMP (M.A.305(c)(3) and M.A.305(e)(2)(iii)). If the maintenance was performed off-wing, EASA Form 1 needs to be kept.

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